PRIVACY POLICY
Effective: 24 October 2026
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The controller
Boros Sámuel, sole trader (egyéni vállalkozó), trading as AdTracking, 2100 Gödöllő, Szkíta körút 33. 1a, Hungary, tax number: 46338723-1-33, email: [email protected]. The controller is not required to appoint a data protection officer. The person responsible for privacy matters is Boros Sámuel ([email protected]). -
Legal background
Regulation (EU) 2016/679 (GDPR); Hungarian Act CXII of 2011 on informational self-determination (Infotv.); Hungarian Act CVIII of 2001 on electronic commerce services; Hungarian Act C of 2003 on electronic communications; Hungarian Act C of 2000 on accounting. -
Processing activities
3.1. Website operation and security
Data: IP address, browser type, time of visit, technical log data.
Purpose: serving the website, security, preventing abuse.
Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
Retention: according to the hosting provider's log rules, for a short period.
3.2. Statistics and advertising measurement (cookies)
Data: cookie and device identifiers, actions on the website (e.g. page views, purchases), approximate location, device and browser data.
Purpose: measuring website use and the effectiveness of advertising, and targeting advertising.
Legal basis: consent (Art. 6(1)(a) GDPR; Hungarian Act C of 2003, section 155(4), and the equivalent ePrivacy rules of your country). Without your consent these cookies are not set. You can withdraw consent at any time through the "Cookie settings" link.
Retention: as stated in the Cookie Policy.
For the Meta Pixel, the Provider and Meta Platforms Ireland Limited are joint controllers for the collection and transmission of data.
3.3. Contact
Data: name, email address, company name, website address, content of the message (via contact form, intake form or email).
Purpose: answering enquiries, providing quotes.
Legal basis: steps prior to entering into a contract (Art. 6(1)(b)) or legitimate interest (Art. 6(1)(f)).
Retention: 1 year from the last contact; if a contract is concluded, as set out in section 3.4.
3.4. Orders and performance of the contract
Data: contact person's name and email, company name, address, tax or VAT number, details of the ordered service, contractual communication.
Purpose: concluding and performing the contract, communication, client records.
Legal basis: performance of a contract (Art. 6(1)(b)).
Retention: 5 years after the contract ends (limitation period).
3.5. Invoicing
Data: the data on the invoice.
Purpose: issuing and keeping invoices.
Legal basis: legal obligation (Art. 6(1)(c); Hungarian Act C of 2000, section 169).
Retention: 8 years.
3.6. Payment
Card payments are processed by Stripe. The Provider does not see or store card details. Stripe also processes payment-related data as an independent controller (for example for fraud prevention), under its own privacy policy.
3.7. Newsletter
Data: email address.
Purpose: sending professional content and offers.
Legal basis: consent (Art. 6(1)(a)).
Retention: until you unsubscribe. You can unsubscribe in every email. Each email contains the sender's name and postal address.
3.8. Source measurement
The origin of visitors who arrive through campaign links is kept in the "at_attr" cookie, set only with your consent (see section 3.2 and the Cookie Policy). Without consent, the information stays in the link and in browser memory only, without being stored.
Retention: 180 days. -
Processors and recipients
Provider Role Registered office Transfer to third countries Cloudflare, Inc. Hosting, DNS, form handling 101 Townsend St., San Francisco, CA 94107, USA EU–US Data Privacy Framework (DPF) Apple Distribution International Ltd. Email account (iCloud Mail) Hollyhill Industrial Estate, Hollyhill, Cork, Ireland Some data may also be stored in the USA; DPF Plus Five Five, Inc. (Resend) Sending form notification emails 2261 Market Street #5039, San Francisco, CA 94114, USA Data processing agreement and standard contractual clauses (SCC) Stripe Payments Europe, Limited Card payments 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland Data may be transferred to the USA; DPF Billingo Technologies Zrt. Invoicing 1133 Budapest, Árbóc utca 6., Hungary None Mango Technologies, Inc. (ClickUp) Client records, project management 350 10th Ave, 5th Floor, San Diego, CA 92101, USA Data processing agreement and standard contractual clauses (SCC) PandaDoc, Inc. Electronic signature San Francisco, California, USA EU–US Data Privacy Framework (DPF) Google Ireland Limited Google Tag Manager, Google Analytics 4, Google Ads Gordon House, Barrow Street, Dublin 4, Ireland Data may be transferred to the USA; DPF Meta Platforms Ireland Limited Meta Pixel Merrion Road, Dublin 4, D04 X2K5, Ireland Data may be transferred to the USA; DPF Apart from the above, personal data is disclosed to third parties only where required by law (for example at the request of an authority).
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Security
Data is processed over encrypted connections in access-protected systems, and only to the extent necessary for the purpose. -
Your rights
You have the right to:
– obtain information and access your personal data,
– have it corrected,
– have it erased or its processing restricted,
– object to processing based on legitimate interest,
– receive your data in a portable format,
– withdraw consent at any time (this does not affect processing before withdrawal).
Send your request to [email protected]. I respond within one month at the latest. -
Remedies and supervisory authorities
You may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):
Address: 1055 Budapest, Falk Miksa utca 9–11., Hungary
Postal address: 1363 Budapest, Pf. 9.
Email: [email protected]
Website: https://naih.hu
You may also lodge a complaint with the supervisory authority of the EU country where you live or work, or where the alleged infringement took place. You may also go to court. -
Visitors outside the EU
United Kingdom and Switzerland. Where the UK GDPR or the Swiss Federal Act on Data Protection applies, you have equivalent rights and can contact me at [email protected]. You may also complain to the UK Information Commissioner's Office (ico.org.uk) or the Swiss Federal Data Protection and Information Commissioner (edoeb.admin.ch).
United States (including California). I do not sell personal information for money. Advertising and analytics tools (Google, Meta) receive data only after you give consent, and third parties can collect information about your online activity over time and across sites only through those tools. Our tags do not load without your consent. You can ask to review, correct or delete your information at [email protected].
Canada. Where Canadian privacy law applies (PIPEDA or Quebec's Law 25), you can ask to access or correct your personal information, or withdraw your consent, at [email protected]. The person responsible for privacy is Boros Sámuel ([email protected]). You may complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca) or, in Quebec, the Commission d'accès à l'information (cai.gouv.qc.ca). I send marketing emails only with your consent, identify myself in every message, and honor unsubscribe requests within 10 business days. -
Changes
The Provider may amend this policy. The current version is always available on the website.