MyPro AI Coach
MyPro Solutions Kft. (registered office: 1149 Budapest, Bíbor utca 7. 1st floor 27., tax number: HU32008595, represented by: Managing Director Elvira Bernadett Dobos, hereinafter: Data Controller), on the basis of Regulation (EU) 2016/679 (hereinafter: Regulation or GDPR), in order to ensure full compliance with the provisions of law, establishes this Privacy Notice (hereinafter: Notice) regarding the personal data processed during the use of the service called MyPro AI Coach (hereinafter: Service), which the Data Controller places at its registered office and publishes on its website (mypro.hu) and makes it available there to everyone.
Data Controller:
Company name: MyPro Solutions Kft.
Registered office: 1149 Budapest, Bíbor utca 7. 1st floor 27.
Tax number: HU32008595
Website: mypro.hu;
E-mail: [email protected]
Represented by: Managing Director Elvira Bernadett Dobos
E-mail: [email protected]
The scope of this Notice applies to the Data Controller and to those natural persons whose personal data the Data Controller becomes aware of and processes during the use of the MyPro AI Coach service (hereinafter: MyPro AI Coach or Service). This Notice enters into force on the date of its signature and remains in force until the date of its withdrawal/amendment.
The Data Controller also records in this document and informs you that MyPro AI Coach may be used exclusively by persons over 18 years of age.
We kindly ask you that during the use of the MyPro AI Coach service you share with MyPro AI Coach only those personal data about yourself that are strictly necessary for the effective use of MyPro AI Coach.
We kindly ask you that during the use of the MyPro AI Coach service you share with MyPro AI Coach only those special categories of personal data about yourself that are strictly necessary for the effective use of MyPro AI Coach.
We kindly ask you not to share personal data relating to other natural persons during the use of MyPro AI Coach.
We inform you that the GDPR shall apply to personal data processing carried out during the use of MyPro AI Coach.
Name of the Service: “MyPro AI Coach”
Brief description of the essence of the Service:
MyPro AI Coach is an AI-based development applying coaching methodology. Within the system, the user may conduct conversations and AI-based coaching processes with several AI coaches of pre-programmed styles. The system explicitly applies coaching methodology.
During the use of MyPro AI Coach, the processing of personal data takes place as follows.
We inform you that you may learn about our packages in the GTC. By subscribing to a package you become entitled to use MyPro AI Coach. Subscription is available both as a natural person and as a business entity (in such case the Employer registers and the users will be the designated employees).
Purpose of processing: registration for the MyPro AI Coach service
Natural person registering in the MyPro AI Coach application:
We inform you, as data subjects, that MyPro AI Coach applies pseudonymization serving the protection of personal data. The Data Controller can establish identity at most from the e-mail address (if it contains the full name), however this is stored separately in a password-protected manner. We also inform you that we store all personal data indicated in this section separately in order that the identity and activity of the given subscriber may become knowable only as the result of a multi-step process.
Legal basis of processing:
In the case of a natural person subscriber: performance of a contract (Article 6(1)(b) GDPR).
The provision and processing of the personal data indicated in this section are necessary for the performance of the contract and are a precondition for concluding the contract. The data subject is obliged to provide the personal data because otherwise they cannot conclude the contract and therefore we cannot ensure the use of the MyPro AI Coach application. The data subject has the right to data portability, i.e., the data subject is entitled to receive their data in a structured, machine-readable format and to transmit them to another controller.
In the case of a business entity subscriber, the employee using MyPro AI Coach: the data subject’s consent (Article 6(1)(a) GDPR); in the case of the administrator: the legitimate interest of the controller (Article 6(1)(f) GDPR).
For administrators: We become aware only of the administrator’s e-mail address. Legitimate interest: providing the service to the company’s employees and, for this purpose, maintaining contact and coordination. We have carried out the legitimate interest assessment test. The administrator, as data subject, has the right to object, given that the legal basis of processing in their case is Article 6(1)(f) GDPR. On the basis of the right to object, the data subject is entitled to object at any time to the processing of personal data concerning them based on Article 6(1)(f). In such case, the controller may no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
For employees: The data subject gives their consent to the processing of personal data during the first use of MyPro AI Coach by ticking a checkbox. Pre-ticking the checkbox is prohibited. During first use, the Data Controller makes the Privacy Notice available via a link, from which the Privacy Notice is directly accessible.
For natural person registrants: The data subject gives their consent to the processing of personal data during registration by ticking a checkbox. Pre-ticking the checkbox is prohibited. During registration, the Data Controller makes the Privacy Notice available via a link, from which the Privacy Notice is directly accessible.
Categories of data subjects affected by processing: subscribers to the MyPro AI Coach service, who may belong to the following categories of data subjects:
Employees of the Data Controller, and the processors indicated in this Privacy Notice.
We delete your data after 1 (one) year has elapsed following the termination of the subscription.
Part of the data is provided by the data subject during registration (e-mail address/username, date of birth), and the other part is generated by the system (code created by a hashed algorithm, 42-character code string, ID identifier).
We do not transfer the data recorded in this section to an international organization or to a third country. We inform you that the personal data recorded in this section are not accessed by OpenAI. We apply pseudonymization, therefore OpenAI never receives data from which identity can be established. Therefore we ask you that during the use of MyPro AI Coach you also do not provide personal data suitable for establishing identity.
The Data Controller uses the processors indicated in Section III.
No automated decision-making – including profiling – takes place.
Purpose of processing: use of MyPro AI Coach, provision of the service
Data concerned by processing:
Natural person using MyPro AI Coach:
- personal data provided about themselves.
During use by the user (i.e., while the user is conversing with MyPro AI Coach), the user may communicate numerous and diverse personal data to the system.
We inform you, as data subjects, that MyPro AI Coach applies pseudonymization serving the protection of personal data.
On the one hand, this means that we, as controller, can establish identity at most from the e-mail address (if, for example, it contains your full name), however we store it separately in a password-protected manner. We also inform you that we store all personal data indicated in this section separately in order that the activity of the given subscriber may become knowable only as the result of a multi-step process.
We also inform you that during data transfer (see point B 1.8.) the system also transfers pseudonymized data to OpenAI, i.e., OpenAI is not able to establish identity on the basis of the data transferred by us and our system.
We ask you that you also do not provide identifying data during the use of MyPro AI Coach.
We recommend that during the use of the MyPro AI Coach application you provide only such personal data about yourself as are strictly necessary for you to use the application effectively and in a manner corresponding to its purpose.
Legal basis of processing:
In the case of a natural person subscriber: performance of a contract (Article 6(1)(b) GDPR).
The provision and processing of the personal data indicated in this section are necessary for the performance of the contract.
In the case of a business entity subscriber, the employee using MyPro AI Coach: the data subject’s consent (Article 6(1)(a) GDPR).
For employees: The data subject gives their consent during the first use of MyPro AI Coach by ticking a checkbox. Pre-ticking the checkbox is prohibited. During first use, the Data Controller makes the Privacy Notice available via a link, from which the Privacy Notice is directly accessible.
For natural person registrants: The data subject gives their consent during registration by ticking a checkbox. Pre-ticking the checkbox is prohibited. During registration, the Data Controller makes the Privacy Notice available via a link, from which the Privacy Notice is directly accessible.
Categories of data subjects affected by processing: subscribers to the MyPro AI Coach service, who may belong to the following categories of data subjects:
Categories of recipients (who are entitled to access personal data): employees of the Data Controller and the processors indicated in this Privacy Notice (hosting providers).
We delete your data after 1 (one) year has elapsed following the termination of the subscription.
Personal data are provided by the user; therefore they originate from the data subject.
We inform you that the MyPro AI Coach system uses artificial intelligence technology provided by OpenAI for generating responses. Accordingly, we have concluded a data processing agreement with OpenAI Ireland Ltd., a company registered in Europe (Ireland); however, its parent company is a company registered in the United States, named OpenAI L.L.C.
Accordingly, OpenAI Ireland Ltd. qualifies as a data processor, and data transfers may occur to OpenAI L.L.C.
The textual messages provided by the user are transmitted to OpenAI’s servers, which are located in Ireland; however, the parent company may also potentially access the data in the United States.
As data controller, we are committed to protecting your data; therefore we developed MyPro AI Coach so that as little personal data as possible are transferred to OpenAI. Accordingly, we apply pseudonymization, therefore the MyPro AI Coach system does not transfer the users’ identifying personal data (see Section II.1.2.) to OpenAI. Thus, OpenAI cannot identify which user of MyPro AI Coach entered the given text.
Within the text you provide during use, the personal data suitable for identification that the system recognizes as personal data (e.g., name) are masked (pseudonymized) during conversation, thereby protecting such personal data from transfer as well. However, it may occur that MyPro AI Coach does not recognize the nature of the disclosed information as personal data suitable for identification and does not perform pseudonymization accordingly. In such case, personal data may be transferred to OpenAI.
We also inform you that personal data which are not direct identifiers, but for example how you feel, what emotions you have, and any information that relates to you and that you provide to MyPro AI Coach during use, are in all cases transferred (as MyPro AI Coach is not capable of recognizing the nature of such personal data) to OpenAI. Therefore, please use MyPro AI Coach with this awareness and make use of our service in knowledge of this information. We recommend that you provide only strictly necessary personal data during use.
It is also important that during use of the system you do not provide personal data about other natural persons (for example name, e-mail address, phone number, health data or any other information concerning another natural person), because such data are not always automatically distinguishable for the AI system and therefore may be transferred to OpenAI.
With regard to your own personal data, we also recommend that during the use of the MyPro AI Coach application you provide only such personal data about yourself as are strictly necessary for you to use the application effectively.
Given that, due to the above, data transfer under the GDPR takes place, we fulfil our detailed information obligation regarding such transfers as follows.
Detailed information regarding the data transfer:
Identification of the business entity to which the transfer is made:
OpenAI, L.L.C.
3180 18th Street
San Francisco, CA 94110
United States
Activity performed by OpenAI:
Personal data transferred during the transfer: the MyPro AI Coach system uses artificial intelligence technology provided by OpenAI to generate responses.
These are personal data that users of the MyPro AI Coach application provide during conversation with MyPro AI Coach and that the system does not recognize as personal data; therefore it does not pseudonymize them (i.e., does not mask them). These are not only direct identifiers that the user enters about themselves or another person (for example name or address, etc.) but may be any information relating to the user or another person (e.g., hair colour, health status, any characteristic of the person, feelings, thoughts, etc.).
Purpose of the transfer: in order to operate effectively, MyPro AI Coach uses artificial intelligence technology provided by OpenAI to generate responses. As a result, it is necessary that certain personal data are transferred to OpenAI L.L.C.
Legal basis of the transfer: the data subject’s explicit consent, which is given during registration (natural person subscriber) or during first use (employees, managing director, members).
Safeguards: Data transfer takes place to the United States, for which the European Commission has not adopted an adequacy decision in respect of OpenAI.
Accordingly, the safeguard for the transfer is the Standard Contractual Clauses (SCC) adopted by the European Commission, which provide appropriate safeguards for the enforcement of data subject rights.
The SCC were developed by the European Commission so that if personal data are transferred outside the EU (e.g., to the USA), these clauses guarantee EU-level protection. Most international service providers (including OpenAI) incorporate the SCC into their own DPA.
Thus, both are included in one document.
A Data Processing Addendum (DPA) has been concluded between the Data Controller and OpenAI Ireland Ltd. We provide a copy of the DPA upon your request.
Hosting providers: DigitalOcean, LLC and Vercel Inc.
We inform you that hosting services are provided by the two business entities indicated in this section on their European (Frankfurt) servers. However, given that both hosting providers are business entities registered in the United States, it may occur that the parent companies access the personal data, which qualifies as a transfer to a third country; therefore we provide the following information.
Personal data transferred during the transfer: all personal data stored in the MyPro AI Coach database.
Purpose of the transfer: provision of hosting for MyPro AI Coach.
Legal basis of the transfer: the data subject’s explicit consent, which is given during registration (natural person subscriber) or during first use (employees, managing director, members).
Safeguards: Data transfer takes place to the United States, for which the European Commission has not adopted an adequacy decision regarding the hosting providers indicated in this section.
Accordingly, the safeguard for the transfer is the Standard Contractual Clauses (SCC) adopted by the European Commission, which provide appropriate safeguards for the enforcement of data subject rights.
The SCC were developed by the European Commission so that if personal data are transferred outside the EU (e.g., to the USA), these clauses guarantee EU-level protection.
The Data Controller uses the processors indicated in Section III.
No automated decision-making – including profiling – takes place.
We inform you that we use the following hosting providers in order to ensure an appropriate and secure IT background.
Name: DigitalOcean, LLC
Contact: 105 Edgeview Drive, Ste. 425 Broomfield, CO 80021
Processing activity: hosting service
Name: Vercel Inc.
Contact: 440 N Barranca Avenue #4133 Covina, CA 91723 United States
Processing activity: hosting service
With regard to the hosting providers, we inform you that in both cases these are business entities registered in the USA, but they provide the hosting service on European servers, i.e., personal data are physically stored in Europe.
Because the providers have a U.S. seat, it may occur that they access personal data, which qualifies as a transfer to a third country. The transfer takes place on the basis of the Standard Contractual Clauses (SCC) adopted by the European Commission; in addition, providers protect data security with appropriate technical and organizational measures and act under a GDPR-compliant data processing agreement.
OpenAI Ltd.
The MyPro AI Coach system uses artificial intelligence technology provided by OpenAI to generate responses.
Name: OpenAI Ireland Ltd
Company registration number: 737350
Registered office / registered address: 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland
Processing activity: provision of artificial intelligence technology provided by OpenAI for MyPro AI Coach to generate responses.
Right of access: The data subject is entitled to receive information as to whether their personal data are being processed and to request access to such data.
Right to rectification: The data subject may request that inaccurate or incomplete personal data be corrected or supplemented.
Right to erasure: The data subject may request the deletion of their personal data, for example if the data are no longer necessary, or they withdraw their consent.
Right to restriction of processing: The data subject may request restriction of the use of data; may request that their data be processed only in a limited manner.
Right to data portability: The natural person subscriber, as data subject, is entitled to receive their data in a structured, machine-readable format and to transmit them to another controller. (Section II.1.3.)
Right to object: applies to administrators, see Section II.1.3.
Right to withdraw consent (only in case of consent as legal basis): The data subject may withdraw their consent at any time without affecting the lawfulness of processing prior to withdrawal.
Right to lodge a complaint: The data subject may lodge a complaint with the supervisory authority (in Hungary: the National Authority for Data Protection and Freedom of Information, NAIH) if they feel that their rights have been infringed.
Right to an effective judicial remedy: If the data subject believes that the controller or processor has infringed the GDPR and personal data are processed unlawfully, they may go to court for remedy.
The Data Controller also specifically informs the data subject that they may withdraw consent at any time by sending a written statement to the Data Controller’s postal address or e-mail address. Withdrawal does not affect the lawfulness of processing carried out earlier.
By post: 1149 Budapest, Bíbor utca 7. 1/27.
By electronic mail: [email protected]
The data subject’s right to lodge a complaint and to seek remedy
We recommend that before initiating the procedures indicated in this section of the Notice, you contact our Company with your complaints, remarks, and questions at any of the contact details indicated above.
Right to lodge a complaint with the supervisory authority
The data subject may exercise the right to lodge a complaint at the following contact details:
National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság)
Registered office: 1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1363 Budapest, Pf.: 9.,
Telephone: +3630 6835969, +3630 5496838, +361 3911400
Fax: +361 3911410
E-mail: [email protected]
Website: naih.hu
Proceedings against the supervisory authority must be initiated before the court having jurisdiction where the supervisory authority has its seat.
Right to a judicial remedy
The action may be brought by the data subject—at their choice—before the competent tribunal having jurisdiction according to their place of residence or place of stay.
1. The Data Controller facilitates the exercise of the data subject’s rights. The Data Controller may not refuse to comply with a request for exercising the data subject’s rights unless it demonstrates that it is not in a position to identify the data subject. The Data Controller assesses the request submitted by the data subject within the shortest possible time from submission, but no later than within 1 month, and informs the data subject of its decision (in writing, or if the data subject submitted the request electronically, electronically).
The request may be submitted as follows:
By post: 1149 Budapest, Bíbor utca 7. 1/27.
By electronic mail: [email protected]
We recommend that before initiating the procedures indicated in this Notice, data subjects contact our Company with their complaints, remarks, and questions at any of the contact details indicated in this section.
In matters not regulated in this Notice, the following legislation shall apply, among others:
a) Section 2:43 of Act V of 2013 on the Civil Code (Hungarian Civil Code);
b) Regulation (EU) 2016/679 (GDPR).
Budapest, October 1, 2025
MyPro Solutions Kft.
Data Controller