Data Privacy Notice in Relation to an Internal Investigation

Ongoing Internal Investigation

Magyar Telekom Távközlési Nyrt., through its Audit Committee (the "Company") is conducting an independent internal investigation (the "Investigation") and has retained White & Case to conduct the Investigation.

The Investigation is inquiring into allegations of possible misconduct related to certain contracts and transactions involving the Company and its Montenegrin or Macedonian subsidiaries. With respect to the Company and its Montenegrin subsidiaries, the Investigation is inquiring into the facts and circumstances arising out of or relating to Sigma Inter Corp., Rawleigh Trading S.A., Fiesta Investments Limited and Activa Invest Ltd. With respect to the Company and its Macedonian subsidiaries, the Investigation is inquiring into facts and circumstances arising out of or related to, among other things, the privatization of Makedonski Telekomunikacii A.D. ("MakTel"), certain consulting and lobbying contracts related thereto and to the subsequent operation of MakTel, including contracts with Cosmotelco Value Added Services S.A., Chaptex Holdings Limited, and/or their affiliates and interactions with government officials related to the operation of MakTel. The Investigation and results of the Investigation are in the legitimate interest of the Company.

The Investigation has been undertaken in view of certain legal obligations of the Company under the laws of Hungary, Montenegro, the Republic of Macedonia, and the U.S.A., including those under the U.S. Foreign Corrupt Practices Act.

Data Collection and Purpose

In conducting the Investigation, Data Managers need to collect and review documents, files and information (including correspondence) relevant to the Investigation (whether in paper or electronic form) in the possession of or under the control of the Companies and its employees.

The information obtained as part of the Investigation includes information that relates to individuals who are current or former employees or staff of the Companies and third parties who have had dealings, directly or indirectly, with the Companies or such employees or staff ("Personal Data").

Personal Data will only be collected by the Data Managers for the purposes of conducting the Investigation and will not be used for any other purpose or after the closing of the Investigation without the express permission of the Company. Data Managers and Data Processors will endeavor to comply with all relevant data protection legislation. White & Case will report its findings and conclusions to the Audit Committee of the Company, and, upon the Company’s request and authorization, may also share information learned during the Investigation with law enforcement authorities in any of Hungary, Montenegro, Macedonia and the United States of America.

It is not in the interest of the Investigation to collect personal correspondence, documents or files that are not relevant to the Investigation or which comprise sensitive or special personal data, being personal data which reveals racial origin, membership of an ethnic minority, political opinions, political party preferences or affiliations, religious or philosophical beliefs, trade union or interest group membership, data concerning health, addictions or sexual life and personal data relating to an individual or an individual’s criminal record that comes into existence, during or prior to the conduct of criminal proceedings, in connection with the crime concerned or such criminal proceedings, at authorities responsible for conducting criminal proceedings, investigating criminal conduct or executing sentences. Files, documents and correspondence that are not relevant to the Investigation are separated from those files, documents and correspondence that are relevant, in order to ensure that only those materials that are relevant to the Investigation are used.

If, despite the efforts of the Data Managers to separate personal materials from those that are business-related, any non-relevant, personal files, documents or correspondence remain among the materials that are examined, such files, documents and correspondence will be ignored for the purposes of the Investigation and will be separated from those materials that are relevant to the Investigation.

The Company and White & Case have retained forensic accountants AlixPartners to provide professional services related to the Investigation, including conducting a forensic accounting examination as part of and with respect to the above Investigation, and a review of accounting and financial controls, policies and procedures related to the Investigation. The Company and White & Case have also retained forensic expert Stroz Friedberg and may retain one or both of the Translators.

In the context of the Investigation, the Companies and White & Case may need to make available Documents containing Personal Data to (i) CGSH, who are responsible for advising the Company on reporting and disclosure matters under Hungarian and U.S. securities laws, (ii) Cadwalader and CM, who are advising the Company in connection with the Investigation, (iii) Debevoise, who are advising Deutsche Telekom AG ("DT") in connection with the Investigation and (iv) to the Company’s auditor, PwC.

Export

As the Company is listed on the New York Stock Exchange and registered with the U.S. Securities and Exchange Commission, and the Data Managers and Data Processors have offices both within the European Economic Area ("EEA") and in the United States of America, Personal Data may need to be exported to member states of the EEA and/or to the United States of America (which latter is a country that does not provide the same level of data protection and privacy as member states of the EEA), in each case in compliance with applicable law.

Confidentiality, Security and Storage

Information received in connection with the Investigation, including Personal Data, will be kept confidential and will only be disclosed in accordance with the terms of this notice and applicable law and in furtherance of the Company’s legitimate interests. Personal Data may be disclosed, as part of the Investigation, (i) among the Companies, the Data Managers and the Data Processors , (ii) by the Companies and the Data Managers to selected third parties (but only where such third parties are contractually or legally bound to keep the data confidential), (iii) to law enforcement authorities in Hungary, Montenegro, the Republic of Macedonia and/or the U.S.A.; or (iv) where the Companies, Data Managers and Data Processors are required to disclose such information pursuant to the laws of the relevant country.

Personal Data will be kept secure using appropriate technical and organizational measures to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, and unauthorized disclosure or access.

Personal Data will only be kept in a form which permits identification of individuals for so long as is necessary for the purposes of the Investigation and in defending against, or cooperating with, any action or procedure of law enforcement authorities in any jurisdiction, or as prescribed by laws or applicable regulations and as described above.

Rights and Remedies

You have the right to obtain from the Data Managers information about your Personal Data that is managed or processed, as provided by applicable law. You also have the right to request the rectification of incomplete or inaccurate Personal Data or have such data erased, to the extent that such right are available to you under applicable law. Where Personal Data is rectified or erased on your request, the relevant Data Manager will inform you and the Recipients of such rectification or erasure, as required by applicable law. You may also have the right to object to the processing of your Personal Data under applicable law. To exercise these rights you must contact the Investigation Data Privacy Officer (as set forth below). A small administration fee may be payable, subject to applicable law.

If you believe that your rights are violated by any of the Data Managers or Data Processors, you may file for court action or turn to the personal data protection commissioner or similar body or authority, as applicable in the relevant jurisdiction.

Questions

If you have any questions about your rights and responsibilities in connection with the management and processing of your Personal Data in the context of the Investigation or you wish to object to the management or processing of your Personal Data, then please contact .

Definitions

1. "AlixPartners" shall mean AlixPartners LLC (2000 Town Center Suite 2400 Southfield, MI 48075, and 9 West 57th Street Suite 3420 New York, NY 10019) and affiliates Alix Partners, Ltd. (20 Balderton Street, London W1K6TL).

2. "Cadwalader" shall mean Cadwalader, Wickersham & Taft LLP (1201 F Street, N.W., Washington D.C. 20004, U.S.A.) and its affiliated foreign offices.

3. "CGSH" shall mean Cleary, Gottlieb, Steen & Hamilton LLP (City Place House, 55 Basinghall Street, London EC2V 5EH, U.K.).

4. "CM" shall mean Crowell & Moring LLP (1001 Pennsylvania Avenue, N.W., Washington D.C. 20004, U.S.A.).

5. "Company" or "Companies" shall mean each of the Company, TCG, Monet, MakTel, Telemacedonia, Stonebridge Communications (under liquidation), T-Mobile Macedonia AD and their respective subsidiaries and affiliates, and other members of the Deutsche Telekom group that may be involved in the Investigation.

6. "Data Managers" shall mean the Companies, White & Case, AlixPartners and CGSH.

7. "Data Processors" shall mean Stroz Friedberg, Cadwalader, CM, Debevoise and the Translators, and such other data processors that may be retained by the Companies in the context of the Investigation.

8. "Debevoise" shall mean Debevoise & Plimpton LLP (555 13th Street, N.W., Washington D.C. 20004, U.S.A.) and its affiliated foreign offices.

9. "PwC" shall mean PricewaterhouseCoopers Könyvvizsgáló és Gazdasági Tanácsadó Kft. (16 Wesselényi u., 1077 Budapest, Hungary) and its affiliated entities.

10. "Stroz Friedberg" shall mean Stroz Friedberg, LLC (1150 Connecticut Ave. NW, Suite 200, Washington, DC 20036, U.S.A.).

11. "Translators" shall mean INTERLEX Communications Kft. (Attila ut 6, Budapest 1013, Hungary) and/or Comprehensive Language Center, Inc. (200 Wilson Blvd., Suite 500, Arlington, VA 22201, U.S.A.).

12. "White & Case" shall mean White & Case LLP (1155 Avenue of the Americas, New York, NY, USA) and its affiliated foreign offices.