CMS is renowned for its well-established and sizeable data protection team, composed of highly experienced and specialised lawyers with strong technical expertise and extensive international reach as well as its ‘deep expertise and pragmatic approach’. The team, led by Dóra Petrányi, a leading data protection lawyer in Hungary, offers a full range of data protection and privacy services. Katalin Horváth, newly promoted to partner, brings expertise in technology, fintech, AI and cybersecurity matters. Márton Domokos coordinates the firm’s CEE data protection practice, focusing on IT, e-commerce, cybersecurity and AI law. Péter Homoki specialises exclusively in IT, data protection and telecommunications law, further strengthening the firm’s capabilities in tackling complex, technology-driven legal challenges.
Data privacy and data protection in Hungary
CMS
Praxisleiter:
Dóra Petrányi
Weitere Kernanwälte:
Katalin Horváth; Márton Domokos; Péter Homoki
Referenzen
‘What truly sets them apart is their deep expertise and pragmatic approach. They are not only well-versed in the complexities of data protection regulations but also excel at providing practical, business-oriented solutions tailored to our specific needs. Their ability to navigate both local and international data privacy laws has been invaluable to our global operations. I would highly recommend them to any business looking for a reliable and forward-thinking partner in data privacy.’
‘Katalin Horváth stands out for her deep understanding of data privacy regulations and her ability to translate complex legal frameworks into practical, actionable advice. What I value most about Katalin is her proactive approach—she anticipates potential challenges and addresses them before they become issues. Her attention to detail, combined with her strong communication skills, makes it easy to trust her guidance. Katalin’s dedication to her clients is unmatched, and her expertise sets her apart from others in the field.’
‘Márton Domokos has been invaluable in managing our data protection needs. His knowledge of data privacy law is vast, but what really differentiates him is his ability to provide tailored solutions that align perfectly with our business objectives. I particularly appreciate his clear, concise explanations of legal concepts, which make complex data protection issues much easier to navigate. Márton’s collaborative and solution-oriented mindset makes him a standout in the field, and his commitment to client service truly distinguishes him from competitors.’
Kernmandanten
Microsoft Hungary
Baumit
BP
Raiffeisen
Kyndryl Holdings, Inc
Samsung Electronics
RTL Group (Bertelsmann Group subsidiary)
Magyar Telekom Plc., IT Services Hungary (Deutsche Telekom subsidiaries)
OTP Mobile Ltd. and HelloPay PLC
Vinted
Highlight-Mandate
- Advising Samsung Electronics on day-to-day data protection matters regulatory issues, contracting procedures and the local feasibility of global features.
- Advising Microsoft on a wide array of data protection matters and their strategic projects for over a decade.
- Advised Partner in Pet Food on the introduction of an AI-powered image processing workplace safety and security software application, including the review of the underlying agreement with the service provider and the analysis of the regulatory (data protection, cyber security and AI) aspects.
Hegymegi-Barakonyi and Fehérváry Baker&McKenzie Attorneys-at-Law
Hegymegi-Barakonyi and Fehérváry Baker&McKenzie Attorneys-at-Law provide comprehensive support in data privacy, protection regulations, incident response and cybersecurity. Its client base spans multinational clients across sectors such as manufacturing, pharmaceuticals, automotive, energy, banking and construction, the team excels in Hungarian and EU data protection laws, with expertise in GDPR compliance projects and region-wide support. The practice advises on data transfer, outsourcing, and internal policies while representing clients before the Hungarian cybersecurity authority, including on NIS2 directive-related matters. It also handles internal investigations on data breaches, compliance, and employment issues and collaborates with European offices on whistleblowing hotline implementation. Team head Csaba Vári is noted for cross-border regulatory and transactional expertise, while András Gaál specialises in data protection, cybersecurity, IT, and IP supporting clients in adopting innovative technologies within compliance frameworks.
Praxisleiter:
Csaba Vári
Weitere Kernanwälte:
András Gaál
Referenzen
‘We can fully rely on their legal advice. We get the legal view very quickly on the topic we asked. I would like to highlight their thorough information sharing related to the legislation, their cooperation in finding solutions and their flexible availability. We are very satisfied with the service provided.’
‘I value the professionalism, the accurate phrasing to help our better understanding, and availability within a short time. Also, their readiness to talk to the global team and explain the local legislation.’
‘Important attributes for us are expertise and speed. The team is excellent in both. They have a very wide and up-to-date knowledge of the topic, not only legal but also business view provided all the time.’
Kernmandanten
TikTok Information Technologies UK LTD
Highlight-Mandate
- Advised TikTok Information Technologies UK LTD regarding the e-commerce, data privacy and competition law aspects of the procedure commenced by the Hungarian Competition Authority, which also involved complex issues regarding the Authority’s powers and jurisdiction.
Lakatos, Köves and Partners
Lakatos, Köves and Partners primarily advise multinational clients on data protection and GDPR matters, offering tailored guidance for market entrants, ongoing business operations, acquisitions and exits. Traditionally active in financial services, energy, and telecoms, the practice has recently attracted major clients in the technology, life sciences and automotive sectors. Key areas of expertise include data protection audits, dispute resolution, incident management, marketing campaigns and product development. Team head Iván Sólyom brings over a decade of experience in data privacy law, providing strategic and practical advice. Zsuzsanna Lukács offers significant expertise in conducting complex data audits, drafting privacy-related policies and agreements, and liaising with Hungarian authorities. Her capabilities extend to data issues in M&A transactions, employment, IT security, e-commerce, and advertising law, enhancing the firm’s versatile offering.
Praxisleiter:
Iván Sólyom
Weitere Kernanwälte:
Zsuzsanna Lukács
Kernmandanten
American International School of Budapest
Mastercard Europe SA
Szentkirályi Kékkúti Ásványvíz, subsidiary of Karlovarské minerální vody
DDB
WHSmith
Xiaomi
Highlight-Mandate
- Advised Mastercard Europe on the data privacy aspects of various new legal projects in Hungary in 2023-2024.
- Advised a global leading confectionery, snacking and petcare business on various consumer and compliance law topics in 2023-2024.
Siegler Bird & Bird Ügyvédi Iroda
With a strong client base spanning the energy, banking and finance, telecoms and media sectors, Siegler Bird & Bird Ügyvédi Iroda delivers robust expertise in intellectual property, tech, communications, dispute resolution and data protection. Its full-service model ensures seamless collaboration across its corporate, commercial, regulatory, finance and dispute resolution practices, offering comprehensive solutions for clients in Hungary and the broader CEE region. The team is particularly renowned for providing international privacy advice to clients in sectors such as automotive, healthcare, banking, ad-tech and telecoms. Co-head Bálint Halász, with a technical background in computer science, excels in IT, privacy, and contentious data protection matters, while Ádám Simon offers extensive experience in data protection and commercial issues across media, tech and telecoms.
Praxisleiter:
Bálint Halász; Ádám Simon
Kernmandanten
Viber
Yettel
HelloPay
Bitrise
Highlight-Mandate
- Advised the founders on the sale of their total shareholding in HelloPay, a Hungarian provider of digital payment solutions.
- Providing data protection support to a Hungarian mobile network operator, advising on a range of complicated data protection issues.
- Represented the leading cross-platform messaging application developer in the competition control proceedings of the GVH for the alleged infringement of unfair business-to-consumer commercial practices in relation to the processing of personal data
Kinstellar Andrékó Ferenczi & Társai Ügyvédi Iroda
Kinstellar Andrékó Ferenczi & Társai Ügyvédi Iroda’s data protection, tech, media and telecoms team, led by Dániel Endre Nagy, is recognised for its expertise in data protection, privacy, IP, copyright and tech and ‘combining local knowledge with global experience’. Nagy brings extensive experience in GDPR compliance, trade marks, cross-border data transfers and privacy audits, offering comprehensive support to in-house teams and advising on whistleblowing policies and disputes. Ákos Nagy adds significant strength with his deep understanding of the regulatory and commercial aspects of the telecoms sector, regularly advising on GDPR compliance, telecom agreements, network arrangements and financing.
Praxisleiter:
Dániel Endre Nagy
Weitere Kernanwälte:
Ákos Nagy
Referenzen
‘The team has an in-depth understanding of diverse data protection regulations and they combine local knowledge with global experience, making them effective in handling multinational cases. The team provides comprehensive support, coordinating across different relevant areas to provide holistic advice that considers all dimensions of data protection.’
‘Nagy Dániel Endre is solution-driven, practical and has an in-depth understanding of the area and relevant fields of the law. He gives quick feedback and works with maximum efficiency.’
Kernmandanten
Vanguards Fashion Group Zrt.
SK Group
GrandVision Hungary Kft.
Parfümerie Douglas GmbH & Co. KG
TiVo Platform Technologies LLC
Zalando SE
Procter & Gamble Magyarorszag Nagykereskedelmi KKT
Highlight-Mandate
- Advising Vanguards Fashion Group Zrt., on continuous data protection legal issues, including the establishment of GDPR compliance.
- Advising SK Group on continuous data protection matters, e.g. setting up its privacy governance structure, setting up of key security systems aimed to protect know-how and other business secrets of the SK Group, preparation of legitimate interest tests, data protection impact assessments, etc.
- Advising GrandVision Hungary Kft. on privacy and advertisement law matters regarding the ongoing marketing operation.
DLA Piper Posztl, Nemescsói, Györfi-Tóth and Partners Law Firm
DLA Piper Posztl, Nemescsói, Györfi-Tóth and Partners Law Firm’s data protection and privacy practice operates across tech, media, life sciences and real estate, handling complex, multi-sector matters with extensive global reach. The team advises leading brands on international compliance issues and is deeply involved in shaping data protection law locally and internationally. Integrated with other departments, the team provides full-service support, including expertise in AI development and innovation. Led by Zoltán Kozma, an expert in tech, media and telecoms, the team also features Márk Almásy, skilled in data protection, IP and life sciences privacy issues, and Fanny Horváth, who advises on compliance, civil law and AI-related matters.
Praxisleiter:
Zoltán Kozma
Weitere Kernanwälte:
Márk Almásy; Fanny Horváth
Kernmandanten
BorgWarner
Rolls Royce Plc.
Wizz Air Hungary Zrt.
AMPLIFON Magyarország Kft.
Highlight-Mandate
- Providing day-to-day assistance for BorgWarner Group’s global operations in all of their privacy-related matters, including vendor connections, intragroup and intracompany issues, and core business functions.
- Providing day-to-day DPO-type assistance for AMPLIFON’s Hungarian operations in all of their privacy-related matters.
KPMG Legal Tóásó Law Firm
KPMG Legal Tóásó Law Firm’s data protection practice supports high-profile multinationals and SMEs across financial, retail, healthcare and manufacturing sectors. Beyond traditional GAP analysis and implementation, the team assists with cutting-edge issues such as software application data flow mapping, data protection due diligence, and whistleblowing regulation compliance. The team also represent clients before the Hungarian Data Protection Authority and in court, leveraging its extensive litigation experience. Co-heads Fanni Márkus and Nora Takacs bring deep expertise in GDPR, digital compliance and sector-specific data protection. Markus focuses on technology and healthcare, advising on biometric and health data, HR policies, and CCTV documentation, while Takacs specialises in GDPR projects and digital services compliance.
Praxisleiter:
Fanni Márkus; Nóra Takács
Referenzen
‘They work well together as a group and have a high level of knowledge. Answers are quick, solutions are highly oriented towards achieving concrete results. They understand the needs of customers.’
‘Each group member has a high level of knowledge.’
Kernmandanten
SANOFI-AVENTIS Zrt
Garantiqa Hitelgarancia Zrt.
Raiffeisen Bank Zrt.
Kometa 99 Zrt.
Amnesty International Magyarország
Amigos a Gyerekekért Alapítvány
EOS Faktor Magyarország Zrt.
Intrum Zrt.
Manpower Munkaerő Szervezési Korlátolt Felelősségű Társaság
Knapp Hungary Kft.
Pediatrics Clinic no. I. of Semmelweis University (Bókay Child Clinic)
Kärcher Hungária Kft.
Melco Mobility Solutions Hungary Kft.
SAS Magyarország Vagyonkezelő Zrt.
eMAG Magyarország Kft.
Grafton Recruitment Kft.
StockX LLC
Dakai Group Kft.
Highlight-Mandate
- Acting as local data protection officer of the Hungarian Sanofi entities, i.e. Sanofi-Aventis Zrt., Chinoin Zrt., Opella Healthcare Hungary Kft., and Opella Healthcare Commercial Kft.. within this mandate we provide continuous data protection support in respect to the daily operation of the companies, including preparation of data protection notifications, data processing agreements, joint data controlling agreements, handling data subjects’ requests and data breaches.
- Providing full-scale data protection support to ALD Automotive Hungary Car Fleet Management and Financing Limited Liability Company in the introduction of telematics services utilising telecommunications, GPS and AI for IoT fleet management (Car2Car solution), including the establishment of the contractual structure relating to the telematics software and the black box as well as the preparation of the underlying data protection documentation.
- Providing full-scale data protection support to Melco Mobility Solutions Hungary Limited liability Company with regard to its business activity of wholesale of car parts and supporting processes (i.e. employment, payroll), including conducting GDPR maturity assessment, preparation of data privacy notices (i.e. CCTV), data privacy policy, document handling policy, interest balancing tests (CCTV, contact persons), DPIA.
Oppenheim Ugyvedi Iroda
Oppenheim Ugyvedi Iroda combines international experience with local expertise, offering cutting-edge advice on evolving topics such as third-country data transfers and AI-based solutions. With a strong regulatory and litigation background, the team has significant experience in regulatory proceedings and data protection litigation, as well as conducting GDPR gap assessments and compliance projects for high-profile clients in sectors such as construction, confectionery and banking. Led by Ivan Bartal, the team excels in e-commerce, copyright, software development, IP/IT transactions and data protection. Bartal has guided global and local companies through GDPR preparation and compliance with local data protection regulations.
Praxisleiter:
Ivan Bartal
Referenzen
‘Very experienced combined with the highest professionalism, very reliable and fast responding, outstanding overall professional performance.’
‘Ivan Bartal has very deep knowledge and experience in the field, focusing on the key points he is capable of providing fast, reliable, outstanding professional solutions.’
‘The practice provides an excellent blend of legal and business advice. What distinguishes the practice from others is strategic thinking: they have tailored legal solutions to the specific needs of the company, to support the decisions needed for the long-term success of the client. This forward-thinking, innovative approach ensures that the company is prepared for emerging regulatory challenges and can quickly adapt to the changing landscape of privacy laws.’
Kernmandanten
Scania
Inditex SA
Ferrero
Samsung
Skanska
LKH Leoni
HELL Energy
Vodafone Shared Services
Bank Gutmann
Volvo
INDITEX SA
4ig
Mediszintech Audiológia Kft.
Highlight-Mandate
PROVARIS Varga & Partners
The privacy, technology and intellectual property team at PROVARIS Varga & Partners is highly specialised earning a strong reputation for its expertise in the Hungarian market. Renowned for handling complex technology and data privacy issues, the team has a notable track record advising health sector clients on data-related legal matters. Co-heads Tamás Bereczki, Ádám Liber, and Zsombor Orbán bring exceptional credentials. Bereczki offers a unique experience in data protection, cyberlaw, and IT, honed in-house at global banks. Liber advises multinationals on EU data privacy law, outsourcing, and regulatory investigations, while Orban is recognised as a leading expert in digital technology and privacy.
Praxisleiter:
Zsombor Orbán; Ádam Liber; Tamás Bereczki
Weitere Kernanwälte:
Olivér Németh
Referenzen
‘Zsombor Orbán stands out due to his extensive experience and deep understanding of the technology sector. His ability to grasp complex technological nuances allows him to provide insightful and relevant advice, particularly in navigating industry-specific challenges. What truly sets him apart is his strategic planning expertise; he consistently delivers long-term solutions that align with both the immediate and future goals of clients. I’ve valued his foresight, ability to anticipate market shifts and his commitment to finding tailored strategies that drive success.’
‘This practice has very thorough and up-to-date knowledge in the respective field. They follow not only the local legislative and authority practice but the international as well.’
‘Speed, efficiency and concentration on the market.’
Kernmandanten
eMAG Magyarország Kft.
Wish US Holdings LLC (d/b/a Wish+)
HACKRATE Kft.
Assa Abloy/FlexiForce Hungary Kft.
Hungarian Tourism Association Foundation
Nestlé Hungária Kft
MSK Hungary Bt.
OTP Bank Nyrt.
Revolut Bank UAB
Leanpay Hungary Zrt.
Highlight-Mandate
Taylor Wessing Hungary
Taylor Wessing Hungary has a strong focus on advising innovative clients in the technology sector, offering full-scale GDPR audits, tailored compliance strategies, and guidance on cross-border data transfers. The team provides proactive advice on the legal implications of emerging technologies and data-driven businesses, serving major international clients to ensure GDPR compliance across the EU. With expertise spanning insurance, health, IP and clinical trials, the team is well-equipped to tackle privacy challenges in AI and life sciences. Led by Dániel Ódor, an expert in GDPR compliance and privacy policies, and supported by János Kopasz, who brings substantial experience in data protection projects, the team delivers comprehensive solutions with extensive international capabilities.
Praxisleiter:
Dániel Ódor
Referenzen
‘Expertise and experience in specific areas of law. A comprehensive and clear understanding of the scope of work. Delivers the legal project always by deadline and in very good quality allocating the right resources. The internal communication within the office is very efficient.’
‘Committed partners with best-in-class expertise. Partners have very good communication skills, are extremely polite and have strong knowledge of substantive and procedural law. Demonstrate engagement in the projects and clients.’
‘The team is very responsive in general, if the client has questions there is always someone in the team who can provide legal advice.’
Kernmandanten
AIP Medical Hungary Kft and AIP Medical Holding Zrt (AIPDerm Medical)
Kontron Hungary Kft
Hiya Inc
Hiya Hungary Kft
CML Construction Services Zrt. (Strabag Hungary)
Angelini Pharma
EIPA Hungária Kft
AKA Zrt and A-WAY Zrt
KRAMP Hungary Kft
Forestay Group
JUNGHEINRICH Hungária Kft.
Ekata Inc.
International Property Network Zrt.
Highlight-Mandate
- Continuing to adapt a privacy governance model for AIPDerm Medical’s latest AI-based teledermatology platform, to align with the latest data governance practices.
- Designed a complete privacy governance model for Kontron Hungary.
- Advising Hiya Inc., a global spam-blocking and caller-identification service provider.
VJT & Partners
VJT & Partners boasts in-depth expertise in high-profile data protection and privacy matters, with particular strength in GDPR compliance. Advising leading Hungarian and international corporates, the team handles a full spectrum of data protection issues, including privacy in technology and data security, across various industries. The practice is co-headed by János Tamás Varga, a leading figure in Hungarian data protection with over two decades of experience, and Endre Várady, an expert in cross-border privacy matters, outsourcing and IT. Andrea Belényi adds significant value with over a decade of experience in regulatory and compliance-focused data protection advice.
Praxisleiter:
János Tamás Varga; Endre Várady
Weitere Kernanwälte:
Andrea Belényi; Fanni Fehér
Referenzen
‘VJT is a well-organised, highly consciously managed law firm. The work processes seem well organised from the outside, and the office works efficiently.’
‘The lawyers I worked with showed maximum professionalism. During the project, they were helpful and proactive.’
‘Andrea Belényi explained in great detail the legislation, what has to be taken into account and what has to be complied with.’
Kernmandanten
4LD
Skechers
Highlight-Mandate
- Advising Google on RTBF matters.
- Advising Google on data-driven products.
CERHA HEMPEL Dezso & Partners
CERHA HEMPEL Dezso & Partners delivers high-level legal services across all aspects of data protection, supported by strong cross-border capabilities and a network of CEE offices offering seamless, one-stop solutions. Co-head Tamàs Polauf provides strategic oversight, while co-head Andrea Presser specialises in drafting notices and agreements for data processors and controllers. Presser’s expertise spans international data transfers, technical measures, intra-group agreements and more, ensuring clients receive tailored, comprehensive advice on complex data protection issues.
Praxisleiter:
Tamás Polauf; Andrea Presser
Weitere Kernanwälte:
Tamás Novák
Referenzen
‘With a highly qualified team, they are available to clients in all legal areas. As a company with a German parent company, it is very important that we can work with professionals with excellent language skills in legal matters.’
‘We work with very direct and helpful professionals.’
Kernmandanten
VerbaLink Europe LLC.
iFLYTEK Co., Ltd.
Galleon Capital Management GmbH
CA Immo Real Estate Management Hungary Ltd.
BERAMAN Hungary Ltd.
Uniqa Raiffeisen Software Service Ltd.
Knauf Insulation Ltd.
Vitesco Technologies GmbH
Highlight-Mandate
- Assisting the Hungarian SPVs of CA IMMO Group in GDPR-related matters.
CLV Partners - Csabai & Partners Law Firm
CLV Partners - Csabai & Partners Law Firm’s data protection practice, bolstered by strong corporate and employment expertise, serves multinational clients in technology, manufacturing, FMCG and HR services. The team offers business-focused advice and has extensive experience establishing GDPR-compliant whistleblowing policies and investigating harassment and whistleblowing cases with privacy by design. Led by Anna Katalin Papp, who specialises in corporate, commercial, employment and data protection matters, the team delivers tailored solutions to meet complex client needs across diverse industries.
Praxisleiter:
Anna Katalin Papp
Weitere Kernanwälte:
Anikó Hrebenku; Eszter Bohati
Referenzen
‘Good partnership, quick answers and reliable cooperation.’
‘They provide practical advice, considering and taking into account all relevant legal circumstances and they work quickly and thoroughly.’
‘Anna Papp strives to provide the most practical and usable solution to the client’s problem. The quality and speed of the service she provides rivals that of larger law firms.’
Highlight-Mandate
Schoenherr Hetényi Ügyvédi Iroda
Schoenherr Hetényi Ügyvédi Iroda’s data protection team works closely with other departments and its CEE network, offering comprehensive services including GDPR compliance, audits and internal policy implementation. The team frequently drafts data protection contracts and advises on employee and HR data management, as well as the data aspects of major corporate transactions. Led by Dániel Gera, a seasoned expert with nearly 20 years of experience, the team advises clients across sectors such as construction, energy, financial services, IT, telecom and the automotive industry.
Praxisleiter:
Dániel Gera
Referenzen
‘Approachable collaboration and down to earth advice.’
Kernmandanten
Geberit
Emirates Telecommunications Group Company
European Union Intellectual Property Office
Fressnapf-Hungária Kft.
B&B Hotels
Highlight-Mandate
- Assisting Fressnapf Hungary with the data protection aspect of their promotions and sales activities.
- Assisted Geberit Hungary in connection with data protection issues, including GDPR audit, retention period of documents, data processing prospectus, employee share scheme and review of the internal GDPR software of the company.
- Advised B&B Hotels Hungary with setting up its internal regulations on data processing activities and also with the establishment of internal processes.
Sándor Szegedi Szent-Ivány Komáromi Eversheds Sutherland
Sándor Szegedi Szent-Ivány Komáromi Eversheds Sutherland’s data privacy practice provides comprehensive advisory services to both multinational and local companies. With extensive experience in GDPR implementation, data breaches, audits, data mapping, and supporting transactions and HR, the team delivers tailored solutions across diverse industries. The team is led by Gergely Dzsinich, a seasoned expert in data privacy. Katalin Varga excels in drafting privacy policies, whistleblowing procedures, and employment-related data protection, the team also represents clients in data breach proceedings before the national data protection authority.
Praxisleiter:
Gergely Dzsinich
Weitere Kernanwälte:
Katalin Varga
Kernmandanten
Autoliv
Eaton
Red Bull
Sunrider
Tata Consultancy Services
Yves Rocher
Highlight-Mandate
- Advising a client with their data protection compliance project, including the preparation of their privacy policies and notices for different data subjects and preparation of contracts for data processing.
- Advising and representing the client within their notification procedure upon a data breach.
- Advising the client in relation to data protection relation aspects of the launch of their new project including the use of AI by autonomous delivery robots.
Wolf Theiss Faludi Ügyvédi Iroda
Wolf Theiss Faludi Ügyvédi Iroda's data protection team, integrated within the employment department, combines expertise in HR-related data protection with strong capabilities in IP/IT and corporate compliance. The international team excels in fully implementing GDPR requirements across multiple jurisdictions. Co-head János Tóth advises on a wide range of data management issues, including outsourcing restrictions, data leaks and cyberattacks, with extensive experience consulting with supervisory authorities. Co-head Barnabás Buzási specialises in data protection compliance, cross-border data transfers and employee monitoring, with significant expertise in handling complex CEE-region projects.
Praxisleiter:
János Tóth; Barnabás Buzási
Referenzen
‘We have found them to be reliable and efficient, and are happy to use them from time to time.’
Highlight-Mandate
- Advising an operator of online marketplace for short- and long-term homestays in respect of certain regulatory aspects of their operations in Hungary, such as the data privacy aspects of their monitoring of communications on their internal messaging platform.