Complaints Policy
Version 1.2 · In force from: 7 October 2026 · This document is provided in English.
ColourSense — personal colour analysis
What is this document for? It sets out how you can make a complaint about the ColourSense service, what the Provider does once the complaint arrives, within what deadlines, and where you can turn if we reject your complaint. The document addresses the Consumer and the inspecting authority at the same time: the Consumer should see what he or she can do; the Provider should see what it must do and by when.
This Policy is the mandatory information required by Section 17/A of Act CLV of 1997 on consumer protection (the "Fgytv."), the Hungarian provision that implements Article 13 of Directive 2013/11/EU on alternative dispute resolution for consumer disputes (the "Consumer ADR Directive"). It does not limit any right to which you are entitled as a consumer under the law.
Related documents: Legal Notice · Terms of Service · Privacy Policy · Withdrawal Information Notice · Cookie and Storage Notice.
A note on the quotations. The Fgytv. has no official English translation. Where this Policy quotes the statute in quotation marks, the quotation is a working translation made for this document; the authentic text is the Hungarian one, reproduced verbatim in the Hungarian-language version of this Policy. Where an EU instrument stands behind the Hungarian rule, the EU provision is cited alongside it.
Contents
| Chapter | Subject |
|---|---|
| 1. | Purpose, scope and legal basis of this Policy |
| 2. | Where to turn with your complaint — the Provider's complaint-handling details |
| 3. | What qualifies as a complaint |
| 4. | Ways of making a complaint |
| 5. | Handling of an oral complaint and the record of the complaint |
| 6. | Handling of a written complaint — acknowledgement and substantive reply |
| 7. | Rejection of a complaint — mandatory information on remedies |
| 8. | Retention of complaint records |
| 9. | Table of deadlines — the Provider's internal procedure |
| 10. | Conciliation Board (békéltető testület) |
| 11. | Consumer protection authority |
| 12. | Cross-border consumer disputes |
| 13. | Court proceedings |
| 14. | Data processing in the course of complaint handling |
| 15. | Publication, amendment, language versions |
| 16. | Version and entry into force |
1. Purpose, scope and legal basis of this Policy
1.1 Purpose
The purpose of this Policy is to enable users of the ColourSense service to learn clearly, in advance and free of charge how a complaint can be submitted, how a complaint is handled, within what deadlines, and what remedies are available if the complaint is rejected.
1.2 Personal scope
| Who | Application of this Policy |
|---|---|
| Consumer — a natural person acting outside the scope of his or her profession, self-employed occupation or business activity (Fgytv. § 2(a); Section 8:1(1) point 3 of Act V of 2013 on the Civil Code, the "Ptk."; Art. 2(1) CRD) | This Policy applies in full, with the mandatory content required by Fgytv. § 17/A. |
| A User who is not a consumer (an undertaking, an organisation) | The Provider receives such reports through the same channels and handles them under the same internal procedure; however, the mandatory deadlines under Fgytv. § 17/A and Conciliation Board proceedings — subject to the exception in section 1.3 — are not available to a notifier who is not a consumer. |
1.3 Extension of the concept of consumer in Conciliation Board proceedings
Fgytv. § 2 point 10 — in the wording in force from 1 January 2026 — treats, for the purposes of the rules on the Conciliation Board, certain civil-society organisations, ecclesiastical legal persons, condominiums and housing cooperatives, and also micro, small and medium-sized enterprises (SMEs), as consumers; the latter, however, only if they use a public utility service or if they purchase, use or take up goods in the course of retail activity within the meaning of the Hungarian Trade Act. ColourSense supplies a digital service, which is neither a public utility service nor goods, and it is therefore doubtful whether an SME customer falls within that category.
1.4 Legal basis
| Legislation | What it governs |
|---|---|
| Act CLV of 1997 on consumer protection (Fgytv.), § 17/A | the mandatory procedure for handling complaints, the content of the record, the 30-day reply, the three-year retention, the information to be given on rejection |
| Fgytv. §§ 18–37/A | Conciliation Board: powers, jurisdiction, procedure, duty to cooperate, declaration of submission |
| Fgytv. §§ 45/A–47 | inspection powers of the consumer protection authority and fines |
| Government Decree 45/2014. (II. 26.) on the detailed rules of contracts between a consumer and a business ("Decree 45/2014."), § 11(1) points d), h), v) and w) | pre-contractual information on the way complaints are handled and on the Conciliation Board (Art. 6(1)(c), (g) and (t) CRD) |
| Government Decree 326/2024. (XI. 14.) | designation of the consumer protection authority |
| Directive 2013/11/EU, Article 13 | information on the alternative dispute resolution entity |
| Act CVIII of 2001 (Ekertv.), § 4 | publication of the Provider's identification data (see the Legal Notice); Art. 5 of Directive 2000/31/EC |
1.5 Relationship to the other documents
- The Provider's identification data, the details of the hosting provider and the contact details of the authorities are set out in the Legal Notice.
- Contractual rights and obligations — including the statutory warranty of conformity (kellékszavatosság), the remedies for non-conformity and the hierarchy of those remedies — are set out in Chapter X of the Terms of Service. If your complaint concerns a defect in the Report or a failure to perform, this Policy does not affect and does not limit your claims under Chapter X of the Terms of Service.
- The right of withdrawal and termination is described in the Information on the right of withdrawal and termination.
- Data processing in the course of complaint handling is set out in detail in the Privacy Policy.
1.6 Material scope
This Policy covers all of the Provider's activities that affect consumers, namely
- complaints concerning the ordering, performance and delivery of the paid colour analysis, the Report, invoicing and payment;
- complaints concerning the free colour test and the e-mails sent on the basis of it (including unsubscribing);
- complaints concerning the Provider's commercial communication and the information given on the website.
The obligations under Fgytv. § 17/A apply irrespective of whether the person making the report has purchased anything from the Provider.
2. Where to turn with your complaint — the Provider's complaint-handling details
Legal basis: Fgytv. § 17/A(1)(a)–(e) — the business must inform the consumer of its name, its registered seat, the place of complaint handling, the way complaints are handled, and of the mailing address, e-mail address, website address and telephone number used for making complaints.
| # | Item | Value |
|---|---|---|
| 2.1 | Name of the Provider | Ágnes Gróf, sole trader (ColourSense) |
| 2.2 | Registered seat | 2100 Gödöllő, Szabó Pál utca 32., Hungary |
| 2.3 | Place of complaint handling | 2100 Gödöllő, Szabó Pál utca 32., Hungary |
| 2.4 | Mailing address for complaints | 2100 Gödöllő, Szabó Pál utca 32., Hungary |
| 2.5 | E-mail address for complaints | support@colour-sense.com |
| 2.6 | Telephone number | +36 30 460 0093 |
| 2.7 | Website | https://colour-sense.com |
| 2.8 | Hours during which these channels are available | on business days from 9:00 to 17:00 (Central European Time) |
Business premises and in-person customer service. The Provider sells exclusively online, does not maintain business premises and does not offer in-person customer service. Your complaint may therefore be made by telephone, by post or by e-mail.
No premium-rate number. The telephone number in row 2.6 is not a premium-rate number: a call costs you no more than an ordinary call (Decree 45/2014. § 6; Art. 21 CRD).
The Provider does not operate a customer service centre within the meaning of Fgytv. § 17/B, because it is not a business carrying out a public utility activity; nor is it required to employ a consumer protection officer (fogyasztóvédelmi referens) under Fgytv. § 17/D. This does not affect the channels and deadlines undertaken in this Policy.
3. What qualifies as a complaint
A complaint is any report in which you object to the Provider's service, its procedure, the performance, non-performance or deficiency of the service, or the conduct of a member of the Provider's staff, and which affects your individual right or interest.
Not a complaint — but an enquiry, which the Provider also answers, although the mandatory deadlines of this Policy do not apply to it:
- a general request for information about the service, the price or the process;
- a request for the Report to be sent again (see section VIII.4 of the Terms of Service);
- a data protection request by a data subject (access, rectification, erasure, etc.) — these are subject to the separate deadlines set out in the Privacy Policy;
- a declaration of withdrawal or termination — governed by the Information on the right of withdrawal and termination.
If the report also contains an objection alongside the above, the Provider handles it as a complaint.
Repeated and unidentifiable complaints. Under Fgytv. § 17/A(9), the investigation of a repeated complaint that is identical in content to an earlier one and contains no new information, and of a complaint submitted by a person who cannot be identified, may be dispensed with. Where the notifier can be identified and contacted, the Provider informs him or her of that fact.
4. Ways of making a complaint
Legal basis: Fgytv. § 17/A(2) — "The consumer may communicate his complaint to the business orally or in writing."
4.1 Written complaint
You may submit a written complaint in the following ways:
| Channel | Contact | Note |
|---|---|---|
support@colour-sense.com |
the fastest route; the reply is also sent by e-mail | |
| Letter by post | 2100 Gödöllő, Szabó Pál utca 32., Hungary | registered post is recommended so that dispatch can be evidenced |
| A reply to the e-mail delivering the Report | a reply to the delivery e-mail arrives in the mailbox in row 2.5 | — the Provider's outgoing transactional messages are sent from an automated sender; the reliable route for a complaint is the e-mail address in row 2.5 |
The requirement of written form is satisfied, under Fgytv. § 17/C, by any means "which enables the addressee to store durably the data addressed to him for a period adequate for the purposes of the data, and to display the stored data in unchanged form and content" — an e-mail therefore qualifies as a written complaint, and the Provider's reply may validly be given by e-mail as well. (The concept corresponds to the "durable medium" of Art. 2(10) CRD; see also § 4 point 9 of Decree 45/2014.)
4.2 Oral complaint
You may make an oral complaint by telephone, on the number in row 2.6, during the period stated in row 2.8. The rules on handling oral complaints are set out in Chapter 5.
As the Provider maintains no business premises, an oral complaint made in person cannot be submitted; the handing over of a record on the spot under Fgytv. § 17/A(3b)(a) therefore does not arise in practice.
4.3 Electronic complaint form
The Provider does not currently operate an electronic complaint interface or form. Should it introduce one in the future, it will acknowledge without delay the receipt of a written complaint at the e-mail address given, as required by Fgytv. § 17/A(6a).
4.4 What it is worth stating in the complaint
To allow a swift investigation on the merits, please include in your complaint:
- your name and the e-mail address or postal address at which you expect the reply;
- the order identifier, or the e-mail address used at payment and the approximate date of the order;
- a detailed description of the objection and the remedy you seek;
- an indication or a copy of the documents, records and other evidence available to you.
Providing these is not a condition of the complaint being accepted. However, under Fgytv. § 17/A(5a), if the consumer does not provide the data referred to in points a) and c) of the record (name and address or e-mail address; the detailed description of the complaint), or refuses to sign it, the business dispenses with the application of paragraph (6) — the 30-day substantive reply — when dealing with the oral complaint.
4.5 Language of the complaint
You may submit your complaint in Hungarian or in English; the Provider replies in the same language. This does not affect the fact that the official language of Conciliation Board proceedings is Hungarian (Fgytv. § 20(6)).
5. Handling of an oral complaint and the record of the complaint
5.1 Immediate examination
Under Fgytv. § 17/A(3), the Provider examines the oral complaint immediately and remedies it where necessary.
5.2 When must a record be taken?
Under Fgytv. § 17/A(3a), if
- you do not agree with the handling of the complaint, or
- immediate investigation of the complaint is not possible,
the Provider takes a record of the complaint without delay and thereafter proceeds in accordance with paragraph (6) — that is, under the regime of the 30-day substantive reply.
5.3 The eight mandatory items of the record
Fgytv. § 17/A(5) (working translation; the authentic text is Hungarian):
"The record taken of a complaint must contain the following: a) the consumer's name and address or e-mail address, b) the place, time and manner of the submission of the complaint, c) a detailed description of the consumer's complaint, and a list of the documents, records and other evidence presented by the consumer, d) the business's statement of its position on the consumer's complaint, where immediate investigation of the complaint is possible, e) the signature of the person taking the record and — save in the case of an oral complaint communicated by telephone or by means of another electronic communications service — of the consumer, f) the place and time of taking the record, g) in the case of an oral complaint communicated by telephone or by means of another electronic communications service, the unique identification number of the complaint, and h) a warning as to the matters set out in paragraph (5a)."
The record taken by the Provider contains all eight items, applied as follows:
| Point | Item | How the Provider applies it |
|---|---|---|
| a) | the Consumer's name and address or e-mail address | for a telephone complaint the name and the e-mail address suffice |
| b) | the place, time and manner of submission | "by telephone", with the date and time of the call |
| c) | detailed description of the complaint; list of the documents, records and other evidence presented | based on what the Consumer states, listing any attachments subsequently sent by e-mail |
| d) | the Provider's statement of its position on the complaint, where immediate investigation is possible | where immediate investigation is not possible, the record states this and the position is given in the substantive reply |
| e) | signature of the person taking the record; for a complaint made by telephone the Consumer's signature is not required | — |
| f) | the place and time of taking the record | the place of complaint handling: 2100 Gödöllő, Szabó Pál utca 32., Hungary |
| g) | for an oral complaint made by telephone, the unique identification number of the complaint | see section 5.5 |
| h) | a warning as to the matters set out in paragraph (5a) | the record warns the Consumer that if he or she does not provide the data under points a) and c), or refuses to sign, the Provider dispenses with the application of the 30-day substantive reply |
5.4 Sending a copy of the record
Under Fgytv. § 17/A(3b), the Provider provides a copy of the record
- for an oral complaint made in person, by handing it over on the spot (this situation does not arise with the Provider — see section 4.2);
- for an oral complaint made by telephone or by means of another electronic communications service, by sending it at the latest together with the substantive reply.
5.5 Unique identification number
Under Fgytv. § 17/A(4), the Provider assigns a unique identification number to an oral complaint communicated by telephone or by means of another electronic communications service, and communicates that number to you during the call as well as in the record and in the substantive reply. Quoting that number, your complaint can be retrieved at any time.
Call recording. The Provider does not record telephone conversations. The obligation to make and retain a sound recording applies to businesses operating a customer service centre within the meaning of Fgytv. § 17/B, a category to which the Provider does not belong (see the closing note to Chapter 2).
6. Handling of a written complaint — acknowledgement and substantive reply
6.1 Acknowledgement of receipt
The Provider acknowledges receipt of a complaint arriving by e-mail without delay, and at the latest on the working day following its arrival, stating in the acknowledgement the identifier of the complaint and the expected deadline for the substantive reply.
The mandatory immediate acknowledgement under Fgytv. § 17/A(6a) — which is tied to an electronic interface or form — does not currently apply to the Provider, because it operates no such interface (see section 4.3); the acknowledgement described above is undertaken by the Provider voluntarily.
6.2 Substantive reply — 30 days
Fgytv. § 17/A(6) (working translation; the authentic text is Hungarian):
"The business is required — unless a directly applicable legal act of the European Union provides otherwise — to reply to a written complaint on the merits, in writing and in a verifiable manner, within thirty days of its receipt, and to take measures for its communication. A shorter deadline may be laid down by legislation, a longer one by an Act. The business is required to give reasons for its position rejecting the complaint."
The Provider's reply accordingly:
| Requirement | How it is met |
|---|---|
| Deadline | 30 days from the receipt of the complaint; the Provider endeavours to reply within a shorter period |
| Written form | by e-mail or — in the case of a postal complaint, or at the Consumer's request — by letter; an e-mail qualifies as written form under Fgytv. § 17/C |
| Substantive content | a reasoned position addressing every element of the complaint and, where the complaint is well founded, an indication of the measures taken or to be taken |
| Verifiable manner | the Provider documents the reply and the fact of its dispatch |
| Statement of reasons | the Provider gives reasons in every case for a position rejecting a complaint |
| Information on remedies | mandatory content where the complaint is rejected — see Chapter 7 |
6.3 If the complaint is well founded
Where the complaint is well founded, the Provider remedies the defect: depending on the nature of the service, by correcting the Report or producing it again, by sending it again, by a proportionate price reduction, or — on the conditions set out in Chapter X of the Terms of Service — by accepting termination of the contract and refunding the fee. The exercise of warranty rights, the hierarchy of remedies and the applicable deadlines are set out in Chapter X of the Terms of Service; this Policy does not narrow them.
Important. A partial refund is not implemented in the system today: a refund can only be initiated by an administrator and always for the full amount. If you request a proportionate price reduction, the Provider handles the claim individually, by manual processing; for as long as a partial refund is not technically available, the Provider refunds the full amount — at your choice. This does not limit the claim conferred on you by Section 22 of Decree 373/2021. Point X.5 of the Terms of Service states the same.
If your complaint concerns the content of the Analysis. The Analysis is produced by artificial intelligence, and the Report is not reviewed by a human colour consultant before it is delivered (section III.5 of the Terms of Service). The undertaking as to a human review of a completed Analysis after delivery is set out in section 5.5 of the Privacy Policy: if you dispute the outcome of the Analysis, the Provider will review it personally at your request and reply in writing within 30 days of receiving your request. What does not in itself amount to non-conformity (disagreement on grounds of taste, inaccurate data supplied by you, a difference caused by the colour reproduction of a screen or a printer) is listed in section X.7 of the Terms of Service; that list does not limit your mandatory consumer rights.
Voluntary money-back undertaking. In addition to the rights conferred by law, the Provider gives the following voluntary undertaking: the Provider does not offer a voluntary money-back guarantee beyond its statutory obligations (section IX.12 of the Terms of Service). This undertaking does not affect or limit your statutory rights.
6.4 The procedure is free of charge
Submitting and investigating a complaint is free of charge for the Consumer.
7. Rejection of a complaint — mandatory information on remedies
Fgytv. § 17/A(8) (working translation; the authentic text is Hungarian):
"Where the complaint is rejected, the business is required to inform the consumer in writing of which authority's or which Conciliation Board's procedure he may initiate with his complaint, according to the nature of the complaint. The information must further contain the registered seat, the telephone and internet contact details and the mailing address of the competent authority and of the Conciliation Board competent for the consumer's place of residence, place of stay or registered seat. The information must also cover whether the business has made a general declaration of submission under § 36/C(1)."
The Provider's rejecting reply therefore contains in every case:
- an indication of which authority or which Conciliation Board you may turn to according to the nature of the complaint;
- the name and contact details of the competent consumer protection authority (Chapter 11);
- the registered seat, telephone contact, internet contact and mailing address of the Conciliation Board competent for your place of residence, place of stay or registered seat (section 10.4), and the fact that you may name any other Conciliation Board in your request (section 10.2);
- the fact of whether the Provider has made a general declaration of submission (section 10.5: the Provider has not made a general declaration of submission);
- the possibility of taking the matter to court (Chapter 13).
Under Article 13(3) of Directive 2013/11/EU, where a complaint submitted directly to the Provider could not be settled, this information must be given on paper or on another durable medium — the rejecting e-mail satisfies that requirement.
8. Retention of complaint records
Fgytv. § 17/A(7) (working translation; the authentic text is Hungarian):
"The business is required to retain for three years the record taken of an oral complaint or the written complaint, as well as a copy of its substantive reply to the complaint, and to present them to the inspecting authority upon request."
The Provider accordingly retains the record taken of an oral complaint, the written complaint and a copy of the substantive reply for three years, and presents them to the inspecting authority upon request.
| Aspect of retention | Content |
|---|---|
| Retention period | 3 years from the receipt of the complaint or from the taking of the record |
| Legal basis of the processing | Article 6(1)(c) GDPR — compliance with a legal obligation to which the Provider is subject (Fgytv. § 17/A(7)) |
| Relationship to an erasure request | while the three-year retention obligation subsists, an erasure request cannot be complied with in respect of the complaint records (Article 17(3)(b) GDPR) |
| Where they are kept today | in the customer service mailbox; incoming mail is not stored in a database by the ColourSense application — the administrator mailbox view opens the mailbox in read-only mode and uses only a short cache of 60 and 300 seconds respectively. The retention rule of the mailbox: 3 years |
9. Table of deadlines — the Provider's internal procedure
This chapter summarises the Provider's own obligations. The table contains every mandatory deadline of complaint handling and of Conciliation Board proceedings.
| # | Event | Deadline | Legal basis |
|---|---|---|---|
| 1 | Examination of the oral complaint and, where necessary, its remedy | immediately | Fgytv. § 17/A(3) |
| 2 | Taking a record where the Consumer does not agree with the handling, or where immediate investigation is not possible | without delay | Fgytv. § 17/A(3a) |
| 3 | Assigning a unique identification number to a telephone complaint | when the complaint is taken | Fgytv. § 17/A(4) |
| 4 | Sending a copy of the record for a telephone complaint | at the latest together with the substantive reply | Fgytv. § 17/A(3b)(b) |
| 5 | Acknowledging receipt of a complaint arriving electronically | without delay (undertaken voluntarily by the Provider; mandatory where a form is operated) | Fgytv. § 17/A(6a) |
| 6 | Substantive, written, reasoned reply in a verifiable manner | 30 days from receipt | Fgytv. § 17/A(6) |
| 7 | Giving the information on remedies where the complaint is rejected | together with the substantive reply | Fgytv. § 17/A(8); Art. 13(3) of Directive 2013/11/EU |
| 8 | Retention of the complaint, the record and the substantive reply | 3 years | Fgytv. § 17/A(7) |
| 9 | Sending a written response to the Conciliation Board | 15 days from service of the board's notice | Fgytv. § 29(8) |
| 10 | Attending the hearing through a representative authorised to conclude a settlement (online at an online hearing; at least online where the Consumer requests an in-person hearing) | on the day of the hearing | Fgytv. § 29(11) |
| 11 | Conclusion of the Conciliation Board procedure (an obligation of the board) | 90 days from the commencement of the procedure, extended by the chair by not more than 30 days in justified cases | Fgytv. § 31 |
| 12 | Notifying the board of the performance of the settlement, of the binding decision, or of compliance with the recommendation | 15 days after the expiry of the deadline | Fgytv. § 36(5a) |
Consequences of a failure. If the Provider breaches the duty to cooperate under rows 9 and 10, the Conciliation Board notifies the consumer protection authority (Fgytv. § 29(12)), and the authority imposes a fine; in the cases falling within this category the minimum amount of the fine is HUF 200,000 (Fgytv. § 47(7)). In addition, under Fgytv. § 36/B the board publishes the name, registered seat and activity of a business that, despite being called upon, made no substantive statement and did not appear at the hearing. Compliance with the information obligations concerning complaint handling and the Conciliation Board is inspected by the consumer protection authority under Fgytv. § 45/A(1)(d)–(e).
10. Conciliation Board (békéltető testület)
10.1 What is the Conciliation Board?
The Conciliation Board (békéltető testület) is an alternative dispute resolution (ADR) entity whose task is the out-of-court settlement of consumer disputes: it primarily attempts to bring about a settlement between the parties and, if that fails, it takes a decision in the case (Fgytv. § 18(1)). The boards operate alongside the county (metropolitan) chambers of commerce and industry and are professionally independent bodies (Fgytv. § 18(2)). The procedure is free of charge for the Consumer and its official language is Hungarian (Fgytv. § 20(6)).
Since 1 January 2024 — under Annex 2 to the Fgytv. — there are eight regional Conciliation Boards.
10.2 Jurisdiction and the free choice of board
Fgytv. § 20(1)–(3) (working translation of the relevant part; the authentic text is Hungarian):
"(1) The procedure falls within the jurisdiction of the Conciliation Board of a) the place of residence or place of stay of a consumer who is a natural person, b) the registered seat of a consumer who is not a natural person. (2) In the absence of a domestic place of residence, place of stay or registered seat of the consumer, the jurisdiction of the Conciliation Board is established by the registered seat of the business … concerned by the consumer dispute. (3) Upon the consumer's request to that effect, the Conciliation Board named in the consumer's request has jurisdiction instead of the board having jurisdiction under paragraphs (1) and (2)."
It follows that:
- Main rule: the board having jurisdiction over your place of residence or place of stay acts.
- If you have no domestic place of residence or place of stay: the board having jurisdiction over the Provider's registered seat acts — that board is: Pest County Conciliation Board (Pest Vármegyei Békéltető Testület) — 1055 Budapest, Balassi Bálint u. 25. IV/2., Hungary · +36 1 792 7881 · pmbekelteto@pmkik.hu.
- Free choice of board: in a request to that effect you may name any other Conciliation Board listed in section 10.4, and in that case the board you name will act. This is your right; the Provider may not restrict that choice.
10.3 Precondition of the procedure — prior direct settlement attempt
Under Fgytv. § 27, a precondition of initiating a Conciliation Board procedure is that the Consumer has attempted to settle the disputed matter directly with the business concerned.
Practical consequence: before turning to a board, please send your complaint to
support@colour-sense.com or to the postal address in row 2.4. The Provider's reply — or the fruitless
expiry of the 30-day deadline — evidences that a prior settlement attempt was made.
10.4 Contact details of the eight Conciliation Boards
Legal basis: Fgytv. § 17/A(1a) — the information must cover "the possibility of having recourse to the Conciliation Boards competent for the consumer's place of residence, place of stay or registered seat", and must state the registered seat, the telephone contact, the internet contact and the mailing address of the Conciliation Board. This obligation must be complied with "in a clear, comprehensible and easily accessible manner", and in the case of a business having a website, on the website.
| Conciliation Board | Territorial jurisdiction | Registered seat | Mailing address | Telephone | E-mail and website |
|---|---|---|---|---|---|
| Budapesti Békéltető Testület (Budapest) | Budapest | 1016 Budapest, Krisztina krt. 99. III. em. 310. | 1253 Budapest, Pf. 10. | +36 1 488 2131 | bekelteto.testulet@bkik.hu · https://bekeltet.bkik.hu |
| Baranya Vármegyei Békéltető Testület | Baranya, Somogy and Tolna county | 7625 Pécs, Majorossy I. u. 36. | 7625 Pécs, Majorossy I. u. 36. | +36 72 507 154 | info@baranyabekeltetes.hu · https://baranyabekeltetes.hu |
| Borsod-Abaúj-Zemplén Vármegyei Békéltető Testület | Borsod-Abaúj-Zemplén, Heves and Nógrád county | 3525 Miskolc, Szentpáli u. 1. | 3501 Miskolc, Pf. 376. | +36 46 501 091 | bekeltetes@bokik.hu · https://bekeltetes.borsodmegye.hu |
| Csongrád-Csanád Vármegyei Békéltető Testület | Békés, Bács-Kiskun and Csongrád-Csanád county | 6721 Szeged, Párizsi krt. 8-12. | 6721 Szeged, Párizsi krt. 8-12. | +36 62 554 250 / ext. 118 | bekelteto.testulet@cskik.hu · https://www.bekeltetes-csongrad.hu |
| Fejér Vármegyei Békéltető Testület | Fejér, Komárom-Esztergom and Veszprém county | 8000 Székesfehérvár, Hosszúsétatér 4-6. | 8050 Székesfehérvár, Pf. 357. | +36 22 510 310 | bekeltetes@fmkik.hu · https://www.bekeltetesfejer.hu |
| Győr-Moson-Sopron Vármegyei Békéltető Testület | Győr-Moson-Sopron, Vas and Zala county | 9021 Győr, Szent István út 10/a. | 9021 Győr, Szent István út 10/a. | +36 96 520 217 | bekelteto.testulet@gymsmkik.hu · https://bekeltetesgyor.hu |
| Hajdú-Bihar Vármegyei Békéltető Testület | Hajdú-Bihar, Jász-Nagykun-Szolnok and Szabolcs-Szatmár-Bereg county | 4025 Debrecen, Vörösmarty u. 13-15. | 4025 Debrecen, Vörösmarty u. 13-15. | +36 52 500 710 | bekelteto@hbkik.hu · https://www.hbmbekeltetes.hu |
| Pest Vármegyei Békéltető Testület | Pest county | 1055 Budapest, Balassi Bálint u. 25. IV/2. | 1055 Budapest, Balassi Bálint u. 25. IV/2. | +36 1 792 7881 | pmbekelteto@pmkik.hu · https://panaszrendezes.hu |
All addresses are in Hungary.
10.5 Declaration of submission
What is a declaration of submission? Under Fgytv. § 36/C(1), a business "may make, in writing and valid until revoked, a general declaration of submission to the Conciliation Board of its registered seat or — with effect covering all Conciliation Boards — to the MKIK, undertaking that it submits to Conciliation Board proceedings and, in the absence of a settlement, to the decision taken in such proceedings". In the declaration the business may also limit the extent or scope of its undertaking to a value of the subject matter of the dispute determined by it, or in another manner.
The Provider's general declaration of submission: the Provider has not made a general declaration of submission.
The absence of a declaration of submission does not mean that the board's decision cannot bind the Provider. Under Fgytv. § 32(a)(ab), the Conciliation Board issues a binding decision even in the absence of a declaration of submission where the request is well founded and the claim the Consumer seeks to enforce does not exceed HUF 250,000 at the time the decision is taken. The price of the ColourSense service (EUR 75.00) is substantially below that amount, and the board may therefore — where the request is well founded — take a binding decision against the Provider even without a declaration of submission, which under Fgytv. § 36(3) may be furnished with an enforcement clause by the court.
10.6 The Provider's duty to cooperate
Under Fgytv. § 29(11), a business is subject to a duty to cooperate in Conciliation Board proceedings. Within that duty the Provider:
- sends a written response within fifteen days of service of the board's notice, in which it states its position on the merits of the Consumer's claim and on the circumstances of the case, and states whether it accepts the panel's decision as binding upon it (submission in the individual case), indicates the facts and evidence supporting its assertions and attaches the relevant documents (Fgytv. § 29(8));
- ensures the participation at the hearing of a person authorised to conclude a settlement; at an online hearing the representative must take part online, and where the Consumer requests an in-person hearing, the representative must take part at least online (Fgytv. § 29(11));
- notifies the board of the performance of the settlement or of the binding decision, or of compliance with what is set out in the recommendation, within fifteen days after the expiry of the deadline (Fgytv. § 36(5a)).
The consequences of a failure are set out at the end of Chapter 9 (notification of the authority, minimum fine of HUF 200,000, publication).
10.7 Mandatory out-of-court dispute resolution mechanism
Beyond the duty to cooperate established by law and described above, the Provider is not bound by any mandatory out-of-court dispute resolution mechanism based on a code of conduct or on a voluntary submission to which it would have subjected itself (Decree 45/2014. § 11(1) point v); Art. 6(1)(t) CRD).
11. Consumer protection authority
Legal basis: Sections 1–2 of Government Decree 326/2024. (XI. 14.) on the designation of the consumer protection authority. Under Section 1, the minister responsible for consumer protection, the National Authority for Trade and Consumer Protection (Nemzeti Kereskedelmi és Fogyasztóvédelmi Hatóság, NKFH), the capital and county government offices, the Government Office of the Capital City Budapest and the Pest County Government Office are designated as consumer protection authorities; under Section 2, "the Government designates the government office as the general consumer protection authority".
The general consumer protection authority acting at first instance. You may turn with your complaint to the body exercising consumer protection powers within the capital or county government office (fővárosi vagy vármegyei kormányhivatal) competent for your place of residence. The contact details of the government offices are available at https://kormanyhivatalok.hu.
The authority competent for the Provider's registered seat is: Pest County Government Office, Consumer Protection Department — 1088 Budapest, József krt. 6., Hungary · +36 1 459 4843 · fogyved@pest.gov.hu.
If you have no place of residence in Hungary. For the purposes of proceedings before the Hungarian consumer protection authority, the government office competent for the Provider's registered seat (Pest County Government Office, Consumer Protection Department — 1088 Budapest, József krt. 6., Hungary · +36 1 459 4843 · fogyved@pest.gov.hu) and the NKFH, which has national competence, act in that case. This does not affect your right to turn to the consumer protection authority of your own Member State or to the dispute resolution forums described in Chapter 12.
The authority with national competence:
| Item | Value |
|---|---|
| Name | National Authority for Trade and Consumer Protection (Nemzeti Kereskedelmi és Fogyasztóvédelmi Hatóság, NKFH) |
| Registered seat | 1122 Budapest, Városmajor utca 35., Hungary |
| Mailing address | 1536 Budapest, Pf. 324., Hungary |
| Telephone (customer service) | 06 80 310 020 (freephone number, reachable only from within Hungary) |
| ugyfelszolgalat@nkfh.gov.hu | |
| Website | https://nkfh.gov.hu |
A precondition of initiating authority proceedings — under Fgytv. § 46(1) — is that the Consumer has first attempted to settle the disputed matter directly with the business concerned. This is the same condition as for Conciliation Board proceedings (section 10.3).
What does the authority examine? Among other things, compliance with the provisions on complaint handling, on dealing with warranty and guarantee claims, on consumer information, on the information to be given about the Conciliation Board (Fgytv. § 17/A(1a)) and on the duty to cooperate in Conciliation Board proceedings (Fgytv. § 29(11)) — Fgytv. § 45/A. Under Fgytv. § 45/B the authority also inspects general terms and conditions to establish whether they contain a term that, contrary to the requirement of good faith and fair dealing, unilaterally and unjustifiably places the consumer at a disadvantage (cf. Article 7 of Directive 93/13/EEC).
The authority does not decide on the contractual claim. The consumer protection authority sanctions the infringement; your individual contractual claim (for example, a refund of the fee) is decided by the Conciliation Board or by the court.
12. Cross-border consumer disputes
The Provider makes the ColourSense service available in several countries. If your place of residence is not in Hungary, the following applies.
12.1 The EU online dispute resolution (ODR) platform has ceased to exist
The European Commission's online dispute resolution (ODR) platform ceased to operate on 20 July 2025 and can no longer be used: Regulation (EU) No 524/2013 was repealed with effect from 20 July 2025 by Article 1 of Regulation (EU) 2024/3228. The platform stopped accepting new complaints on 20 March 2025. The Provider therefore does not refer to the ODR platform and does not place a link to it — such a reference would today be misleading, because it would direct the Consumer to a remedy that no longer exists.
12.2 Alternative dispute resolution (ADR) entity in your own country
You may turn to the alternative dispute resolution (ADR) entity notified to the Commission in your own country under Directive 2013/11/EU. The Commission maintains and publishes the official list of those entities on its website under Article 20(4) of that Directive.
12.3 European Consumer Centres Network (ECC-Net)
In cross-border matters you may obtain free information and assistance from the European Consumer Centres Network (ECC-Net) and from the European Consumer Centre of your Member State of residence. The ECC-Net assists in pursuing claims against a business established in another Member State and in identifying the appropriate dispute resolution forum.
12.4 Hungarian Conciliation Board in a cross-border dispute
In the case of a cross-border consumer dispute connected with an online sales or service contract, Fgytv. § 18(5) confers jurisdiction on the Conciliation Board operated by the chamber designated by decree of the minister responsible for consumer protection. In addition, the Consumer also enjoys the possibilities under Fgytv. § 20(2)–(3): in the absence of a domestic place of residence or place of stay, the board competent for the Provider's registered seat acts, and the Consumer may name any Conciliation Board in the request (section 10.2). The official language of Conciliation Board proceedings is Hungarian (Fgytv. § 20(6)).
13. Court proceedings
The complaint-handling and dispute-resolution possibilities described in this Policy do not affect your right to enforce your claim before a court. Recourse to a Conciliation Board or to an authority is not a precondition of court proceedings, and the Consumer may make use of the two routes one after the other.
The provisions on the applicable law and on jurisdiction are set out in Chapter XIV of the Terms of Service. The Provider applies no exclusive jurisdiction clause: the Consumer may also sue before the courts of his or her Member State of residence, and the mandatory consumer protection rules of the law of his or her habitual residence continue to apply (Articles 17–19 of Regulation (EU) No 1215/2012; Article 6 of Regulation (EC) No 593/2008).
14. Data processing in the course of complaint handling
The details of the data processing connected with complaint handling — the purposes, the legal bases, the categories of data, the retention periods, the recipients and the rights of the data subject — are set out in the Privacy Policy. The points relevant to this Policy are:
| Question | Answer |
|---|---|
| What data do we process? | the data you provide in the complaint: your name, the e-mail address or postal address you give, the order identifier, the content of the complaint and the evidence attached |
| On what legal basis? | performance of the contract (Article 6(1)(b) GDPR); as regards the retention of complaint records, a legal obligation (Article 6(1)(c) GDPR — Fgytv. § 17/A(7)) |
| For how long? | the complaint records and the substantive reply for 3 years; mail arriving in the customer service mailbox is governed by the rule under 3 years |
| Who has access? | the Provider; the operator of the mail server as a processor (the Provider's own mail server) |
| Does the system store the mail in a database? | No. The ColourSense administrator mailbox view opens the mailbox in read-only mode and caches the list for 60 seconds and individual messages for 300 seconds; the content of the mail is not written to a database |
| Can complaint records be erased on request? | while the three-year retention obligation subsists, no (Article 17(3)(b) GDPR) |
Data protection complaint. If your objection concerns the processing of personal data, you may also
raise it at support@colour-sense.com, and you may turn to the Hungarian National Authority for Data
Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH;
1055 Budapest, Falk Miksa utca 9-11., Hungary; mailing address: 1363 Budapest, Pf. 9., Hungary;
https://naih.hu). Under Article 77 GDPR you may also lodge a complaint with the supervisory
authority of the Member State of your habitual residence, place of work or of the place of the
alleged infringement. This does not affect the right of complaint under this Policy.
15. Publication, amendment, language versions
Publication. This Policy is available on the website https://colour-sense.com continuously, free of charge
and without registration, in a downloadable and printable form. The information on the
Conciliation Boards is published by the Provider on the website pursuant to Fgytv. § 17/A(1a); the
same data are also set out in the Legal Notice.
Amendment. The Provider may amend this Policy, in particular where legislation changes or where the contact details of the Conciliation Boards change. The amended Policy enters into force upon publication on the website. Complaints already submitted are dealt with under the Policy in force at the time of submission.
Review. The Provider reviews the data in section 10.4 regularly, at least every six months, because the contact details of the boards may change and the correctness of this information is subject to inspection by the authority (Fgytv. § 45/A(1)(e)). The same commitment is stated in section 6.1 of the Legal Notice; the table in section 10.4 and the table in section 6.1 of the Legal Notice must be updated together, with identical content.
Language versions. This Policy is available in Hungarian and English. If there is a discrepancy between the language versions, the interpretation more favourable to the Consumer prevails.
16. Version and entry into force
| Item | Value |
|---|---|
| Version number | 1.2 |
| Date of entry into force | 7 October 2026 |
| Data last verified (section 10.4) | 25 August 2026 |