Privacy Policy
1. Who We Are
This Privacy Policy explains how KT11 Venture Kft. ('KT11 Venture', 'we', 'us') processes personal data when you visit our website, contact us, subscribe to communications, request selected materials or arrange a meeting.
KT11 Venture Kft. is the controller for the processing described here. Our registered address, company registration information and other legal particulars are set out on our Company Details page: Company Details.
Privacy contact: Thomas Bümsen | thomas.buemsen@kt11-venture.com
2. Personal Data We Process
Depending on your interaction with us, we may process your name, professional contact details, company, the content of messages and enquiries, subscription and consent information, information supplied when requesting selected materials, meeting details, and technical data needed to deliver and protect the website.
Optional analytics and visitor tracking information is processed only where the relevant consent has been given. You can browse public website content without submitting a contact form or subscribing to communications.
3. Website Hosting and Technical Operation
Our website is configured for delivery through Cloudflare infrastructure. Technical information such as IP addresses, request data, timestamps, browser information and security signals may be processed to deliver the website, ensure its availability and protect it against misuse.
The legal basis for necessary website operation and security is our legitimate interest under Article 6(1)(f) GDPR. Cloudflare may process this information on our behalf.
4. Contacting KT11 Venture
You may contact us by email or through the website contact form. We process the details you provide to understand and respond to your enquiry and manage relevant business correspondence.
Depending on the circumstances, the legal basis is Article 6(1)(f) GDPR (our legitimate interest in responding to enquiries and maintaining professional relationships) or Article 6(1)(b) GDPR (steps requested before entering into a contract or performance of a contract).
We use HubSpot to provide and process the contact form. HubSpot may also process technical information needed for form delivery and security. Contacting us does not automatically subscribe you to marketing communications. The form is intended to work without optional analytics or marketing consent.
5. KT11 Venture Insights and Smart People Updates
You may subscribe to communications from KT11 Venture through our website. KT11 Venture Insights provides updates on new Insights, KT11 Venture Monthly and KT11 Venture Specials. Smart People provides information about upcoming Conversations, Events and Dinners. These are separate subscription options. You can choose which communications you wish to receive. When you subscribe, we process your email address, subscription preferences and relevant consent information to provide the communications you have requested and manage your subscription. The legal basis is your consent under Article 6(1)(a) GDPR.
We use HubSpot to manage subscriptions and deliver these communications. Subscription requests are subject to an email confirmation process intended to verify that the request was made by the email address holder. You can unsubscribe at any time using the unsubscribe link included in our communications or by contacting us directly. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
Consent to receive communications is separate from consent to website analytics or visitor tracking. Subscribing to either communication does not automatically authorise optional website tracking.
6. Access to Selected Materials
Certain materials, including the concept brief on creating new businesses in Central and Eastern Europe, may be made available through an access-request form. We process the submitted details to administer the request, provide access and manage relevant business correspondence.
The legal basis is our legitimate interest under Article 6(1)(f) GDPR in providing relevant business materials and responding to professional enquiries; Article 6(1)(b) may apply where the request concerns steps towards a contractual relationship.
HubSpot processes the form submission. Requesting access does not automatically subscribe you to KT11 Venture Insights or constitute consent to unrelated marketing messages.
7. Meeting Scheduling
Where you choose to use HubSpot Meetings, we process the information needed to arrange and manage the conversation, including your name, contact details, selected time and any details you provide.
Depending on the circumstances, the legal basis is Article 6(1)(f) GDPR (our legitimate interest in arranging and managing requested conversations) or Article 6(1)(b) GDPR. The scheduling functionality is initiated when you choose to use it. HubSpot provides the scheduling service.
8. Website Analytics — Plausible
We use Plausible Analytics to understand aggregate website usage and improve our website. Depending on the service configuration, this may involve page views, referring sources and technical information used to compile statistics.
Plausible is activated on the KT11 Venture website only after you consent to the Statistics category. The legal basis is Article 6(1)(a) GDPR. If you decline Statistics, the consent-controlled Plausible script is not activated. You may change your choice through Cookie Settings.
9. Optional HubSpot Visitor Tracking
With your consent, HubSpot visitor tracking may be used to understand website interactions and inform relevant business communications. Depending on the available HubSpot functionality and your interactions with KT11 Venture, website activity may be associated with an identifiable contact record.
HubSpot visitor tracking is activated only after consent to the Marketing category. The legal basis is Article 6(1)(a) GDPR. You can withdraw consent through Cookie Settings. This is separate from unsubscribing from KT11 Venture Insights or Smart People.
We do not use this tracking to make automated decisions producing legal or similarly significant effects.
10. Cookie Consent Management
We use Cookiebot by Usercentrics to present and manage consent choices for cookies and similar technologies. Necessary technologies support website operation; optional technologies are subject to the relevant preferences.
You can accept or reject optional categories and change your choice through the website's Cookie Settings function. Details of the technologies used and their purposes are set out in our Cookie Policy. The cookie declaration is generated for the deployed website and may change as technologies are added or removed.
11. Service Providers and International Transfers
We use service providers for website delivery, communications and website functionality: Cloudflare (hosting and security); HubSpot (forms, subscriptions, scheduling and consent-based tracking); Plausible Analytics (consent-based analytics); Cookiebot / Usercentrics (consent management); Google Workspace (business email); and Spark Mail / Readdle (management of multiple email accounts and scheduled outgoing messages).
We use Google Workspace for business email services and Spark Mail to manage multiple email accounts and schedule outgoing messages. Depending on the functionality used, Spark Mail may process email account information, message content and related metadata to provide these services.
Some providers may process data outside the European Economic Area. Where applicable, transfers are subject to the safeguards required by Chapter V GDPR, such as an adequacy decision or appropriate contractual safeguards. Further information about applicable safeguards can be requested using the contact details above.
12. Data Retention
We retain personal data only for as long as necessary for the relevant purpose and any applicable legal obligations. This includes handling enquiries and professional correspondence, maintaining active subscriptions and appropriate consent evidence, administering access requests, managing meetings, and protecting website infrastructure.
We review professional contact records after 24 months without relevant interaction to assess whether continued retention remains necessary. This review does not mean automatic deletion after 24 months. Subscription information is retained while a subscription remains active; after withdrawal, we may retain limited records necessary to document consent, withdrawal and compliance. Other records are retained according to their purpose, applicable legal retention requirements and legitimate needs to establish or defend legal claims.
13. Your Data Protection Rights
Subject to the conditions in applicable law, you may request access, rectification, erasure, restriction of processing and data portability; object to processing based on legitimate interests; and withdraw consent where processing is based on consent.
To exercise your rights, contact Thomas Bümsen at thomas.buemsen@kt11-venture.com. You may also lodge a complaint with a competent supervisory authority, including the Hungarian National Authority for Data Protection and Freedom of Information (NAIH).
14. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes to our website, processing activities or legal requirements. The current version will be available on this page. Where required, we will provide additional notice or seek renewed consent.