How we handle your data

02What data we collect

We do not collect: the evaluator's name or position - the answers are fully anonymous to the subject. Your answers are never sent to Google. For security we log the IP address and time of requests for a short period (abuse prevention).

03What we use it for

From the evaluators' answers we calculate aggregated scores based on the GROUND leadership model, which the subject views on a private page - individual answers are never shown.

Email addresses are used to send invitations, reminders and confirmations. Quote requests and coaching interest are used to reply to your enquiry. The newsletter goes only to people who ask for it separately when starting their 360 (see 05), never to evaluators.

Anonymised Google Analytics usage statistics help us understand how the tool is used - without any advertising features.

Never: as a selection criterion in an HR system, shared with your manager, or for performance appraisal.

04Legal basis

Your own voluntary consent - GDPR Art. 6(1)(a). The subject consents via the consent checkbox and by starting the 360, the evaluator by submitting the questionnaire, quote and coaching requests by submitting the form, and analytics via the "Accept analytics" button in the cookie bar.

Security logs (IP address, timestamp) are kept on the basis of Y2Y Ltd.'s legitimate interest - GDPR Art. 6(1)(f) - to prevent abuse.

Consent can be withdrawn at any time at info@y2y.hu or by clearing the cookie setting - withdrawal does not affect the lawfulness of earlier processing.

05Köztünk szólva newsletter (only if you ask for it)

When you start your 360, the Köztünk szólva newsletter is a separate, optional checkbox, unticked by default. You get your 360 link without it; we only send the newsletter if you tick the box yourself.

If you tick it, your email address is passed to the Y2Y newsletter system (hirlevel.y2y.hu), which stores: email address, language, time of sign-up, source (mini360) and the exact wording of the checkbox - the latter as evidence of your consent. We send one email a month on leadership and HR.

Legal basis: your separate consent - GDPR Art. 6(1)(a). You can withdraw it at any time with the unsubscribe link at the bottom of every newsletter. Retention: until you unsubscribe. The newsletter is also sent by Resend, as a processor. Details: hirlevel.y2y.hu/adatvedelem.

06Where and how long we store it

The 360 data (answers, email addresses) stays within the EU. Transactional emails are processed by Resend and anonymised usage statistics by Google; any transfer to a third country is covered by EU-approved safeguards (standard contractual clauses or the EU-US Data Privacy Framework). The subject can request the immediate deletion of their 360 and all related data at any time.

07Who receives it

Nobody - not the HR team, not your manager, not an external partner. The evaluators' anonymous answers are seen only by the subject (aggregated, after at least 3 responses). Only Y2Y Ltd. staff bound by confidentiality have access, for system operation.

Our processors, needed to run the service: Netlify (hosting, EU CDN), Supabase (database, EU region), Resend (transactional email: invitations, reminders, confirmations; the Köztünk szólva newsletter if you ask for it), Google Analytics 4 (only after consent; anonymised IP; no advertising features).

One exception: if the subject explicitly asks, the ICF-accredited Y2Y coach may also see the aggregated report for the coaching conversation.

08Automated decision-making

We make no automated decisions about you and there is no profiling with legal effect. Scores are simple arithmetic averages; the final interpretation is done by an ICF-accredited human coach, if you choose to use one.

No live AI model (ChatGPT, Claude etc.) is involved in the questionnaire, the aggregation or the report.

10Complaint to the authority - NAIH

You also have the right to a judicial remedy - at the court competent for your place of residence.