Data Management and Protection Policy

(Privacy Policy)

This policy is compiled in accordance with the legal requirements of the Hungarian legislation in the name of Coinerz Kft. (FullCoin). The policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

We process information about you in accordance with Coinerz Kft.'s Privacy Policy that was compiled in line with the Hungarian Act CXII of 2011 on Informational Self-Determination and Freedom of Information.

Coinerz Kft. is registered with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH). The registration number of Coinerz Kft. is NAIH-140702/2018.

By using our site, you consent to such processing and you warrant that all data provided by you is accurate.

Coinerz Kft. ("we" or "us" or FullCoin) are committed to protecting and respecting your privacy.

This policy together with our Terms and Conditions and any other documents referred to in it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting this website you are accepting and consenting to the practices described in this policy.

For the purpose of the Act CXII of 2011 on Informational Self-Determination and Freedom of Information, the Data Controller is Coinerz Kft. of H-2330 Dunaharaszti, Jendrassik György str. 6.



The Data Controller undertakes to handle the personal data entrusted to it in accordance with all applicable laws, to comply with the statutory data management principles, to comply with the purpose limitation, minimization and security obligations.

It also undertakes to respect the right of information of self-determination of the data and does not disclose personal information to a third party except for statutory obligations.

The principles of data protection serve as guidelines for the company's data management in order to fully comply with the legal requirements for the management of personal data of customers.

The Data Controller is responsible for compliance with the principles and, if necessary, must be able to demonstrate the legality of his or her data management.

Personal data can only be considered as a natural person’s data.

Personal data can only be processed for a predetermined purpose, to the extent and for the duration necessary to achieve the goal.

The management of personal data shall be based on a statutory mandate or - lacking this - the voluntary contribution of the relevant and appropriate information.

In accordance with the principle of fair data management, a data subject may never become a mere subject of a process of personal data management, with respect to the provision of the personal data of the person concerned, with respect to the personal data of the data subject, or to any other person.

According to the data quality principle, the data processed must be accurate, complete and current in accordance with the purpose of data management.

According to the security principle, the data should be protected by reasonable measures appropriate to the state of the art against unauthorized access, alteration, unauthorized disclosure, injury, and destruction.

The fact, location, purpose, data controller and data management policy of the data management must be public.

As a result of the personal participation principle, the person concerned may know, correct, supplement, or delete relevant information in accordance with the relevant legal requirements.

The principles of data management and the obligation to observe them apply to both the Data Controller and subject of data.



Legal basis of data management:

Data management starts with personally filling up personal data and/or accepting our Privacy policy at the verificational steps on our website ( by each user therefore agreeing with our Terms and Conditions and hereby stated Privacy Policy.


Purpose of data management:

The purpose of data management is on one side to help carrying out buy and sell transactions of digital currencies, on the other side data handling and contacting users related to the support, operation and customer service activities throughout the process.

The handling of personal data serves to fulfill the legal obligations in order to prevent the financing of money laundering and terrorist, and, to this end, to cooperate with the authorities, too.

According to our statutory obligations our company cooperates with the authorities and in this connection handles all the data related to the transactions to the authorities at need.

Our Company does not pass on or make available the data it manages for marketing purposes to a third party.




In order to minimize the personal information we receive from our clientele - basically as determined by the amount of transaction - we have created 3 different levels and request personal information from our Clients depending on the levels. You can find out more about these levels in our AML/KYC Policy.


Data that we may require to identify clients:


Other might be recorded data:

The owner of the data is responsible for the accuracy and credibility of the data.

It is in your interest and obligation to disclose your changed personal data with the Data Manager.

The data operator or the service provider company shall not be liable for any disadvantages resulting from the non-fulfillment of the above.

We also may process the following data about you:

Information you give to us. You may give us information about you by filling in forms on ("our site") or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number.

Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:

Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.



Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site, and also allows us to improve our site.

The website also contains links to external servers (not managed by Coinerz Kft.), pages accessible on these links may place their own cookies or other files on the computer, collect data, or request personal information. For these purposes, Coinerz Kft. excludes all liability.




We use information held about you in the following ways:

Information you give to us. We will use this information to:

Information we collect about you. We will use this information:

Information we receive from other sources.



We may share your personal information with any member group, which means our subsidiaries, our ultimate holding company and subsidiaries.

We may share your information with selected third parties including:

We may disclose your personal information to third parties:



The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area ("EEA"). It may be processed by a staff member operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in amongst other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our host provider is Amazon Web Services, Inc. at the moment.



Personal record of user’s data

The user when starting an order on our website (, goes through on a verification process when by accepting our Privacy policy contributes to data management.


Copying the user’s data

The personal data file may be copied if this is unavoidable when examining all other reasonable alternatives, and the copy must be made so that the copy only records the most necessary data.

The Data Controller must be fully acquainted with the purpose of making a copy and must give written consent to it.


Using cameras (web) and recording phone calls

Over a certain AML level our company may initiate a personal contact in the form of a digital call, which can be used to make a video. Recorded video clips are stored for up to 60 (sixty) days.

The legal basis for the recording of telephone conversations is not the voluntary consent of the concerned party, but a statutory delegation: a. Of the Consumer Protection Act 17 / B. Paragraph (3) also stipulates that telephone communications between the customer service and the consumer must be recorded by voice.

If our User does not contribute to fixing the telephone conversation with him/her, our helpdesk service cannot be used for any of our automated services.

The purpose of recording telephone conversations is to protect the data subjects and Data Controller's rights and to guarantee ex post verification.

When recording phone conversations, we store the following data:
phone number, call time, voice recording of recorded conversation, personal information provided during conversation.

We keep the phone conversations for 5 years. The soundtracks are made available by phone number and date of conversation.

In the case of requested data, the recorded audio material will be provided on a data carrier according to the following procedure: the person in question asks for the recording of the recorded conversation, which in the application indicates the telephone number of the device used for the conversation or the time of the conversation (minimum by year, month and day).

To a written request:

The written request will be sent to the registered office of the Company, within 15 days from the receipt of the request, the Company will examine the legality of the information service.

If there is no legal impediment to the provision of information, the Company will send the requested data to the applicant by post, registered mail.

If the information can’t be met, the reason for rejecting the request is returned to the applicant in the unchanged forM.



According to the law, the data IN subject may apply to the Data Controller:


Information on handling personal data

At the request of the person concerned, the Data Controller shall provide information about the data management that he or she is handling by or on behalf of the person concerned.

The Data Controller shall provide the information in writing in the shortest possible time, but not later than 25 days, in an understandable form, at the request of the person concerned.

In the event of denial of information, the Data Controller informs the person concerned of the possibility of a court appeal and of the National Data Protection and Information Authority (hereinafter referred to as "the Authority").


Correction of personal data

If the personal data does not comply with the reality and the personal data corresponding to the reality is available to the data controller, the personal data will be corrected by the Data Controller.



Deleting or blocking personal information, except mandatory data management


Personal data must be deleted, if:


  1. it is illegal to handle it;

  2. the person concerned requests to delete it;

  3. is incomplete or incorrect - and this condition cannot be legally remedied - provided that the termination is not excluded by law;

  4. the purpose of data management has ceased or the statutory deadline for data storage has expired;

  5. it is order by the Court or Authority.

The Terms of Use stipulate that due to the rules and special nature of the Company's services, the cancellation of personal data may be required for a period of at least 5 years after the date on which they are recorded, except for other statutory obligations.

Instead of being deleted, the Data Controller locks out personal data if such request is needed, or if, on the basis of the information available to concerned person, it is assumed that deletion would undermine the legitimate interests of the data subject.

Personal data so locked up can only be handled as long as there is a data management target that excludes the deletion of personal data.

The Data Controller provides a regulatory request based on law, in which the Authority indicates the data requested and the purpose of the data management, to the extent appropriate to the purpose of the request.



Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The Hungarian Act CXII of 2011 on Informational Self-Determination and Freedom of Information gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.



Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.





In case of a request, question, proposal or complaint in regards of data management you can contact the representative of the Data Handler of the Company via the following contact details: [email protected].

You can also turn to the Hungarian National Data Protection and Freedom of Information Authority with any of your complaints in regards of data handling:


Hungarian National Data Protection and Freedom of Information Authority contact details:

Address: Hungary 1125 Budapest, Szilágyi Erzsébet fasor 22/c.

Mailing address: Hungary 1530 Budapest, Pf. 5.

Phone: +36 (1) 391-1400 Fax: +36 (1) 391-1410

Email: [email protected]