PRIVACY POLICY

Effective: 24 October 2026

  1. The controller
    Boros Sámuel, sole trader (egyéni vállalkozó), trading as AdTracking, 2100 Gödöllő, Szkíta körút 33. 1a, Hungary, tax number: 46338723-1-33, email: hello@adtracking.eu. The controller is not required to appoint a data protection officer. The person responsible for privacy matters is Boros Sámuel (hello@adtracking.eu).

  2. 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.

  3. 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.

  4. Processors and recipients

    ProviderRoleRegistered officeTransfer to third countries
    Cloudflare, Inc.Hosting, DNS, form handling101 Townsend St., San Francisco, CA 94107, USAEU–US Data Privacy Framework (DPF)
    Apple Distribution International Ltd.Email account (iCloud Mail)Hollyhill Industrial Estate, Hollyhill, Cork, IrelandSome data may also be stored in the USA; DPF
    Plus Five Five, Inc. (Resend)Sending form notification emails2261 Market Street #5039, San Francisco, CA 94114, USAData processing agreement and standard contractual clauses (SCC)
    Stripe Payments Europe, LimitedCard payments1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, IrelandData may be transferred to the USA; DPF
    Billingo Technologies Zrt.Invoicing1133 Budapest, Árbóc utca 6., HungaryNone
    Mango Technologies, Inc. (ClickUp)Client records, project management350 10th Ave, 5th Floor, San Diego, CA 92101, USAData processing agreement and standard contractual clauses (SCC)
    PandaDoc, Inc.Electronic signatureSan Francisco, California, USAEU–US Data Privacy Framework (DPF)
    Google Ireland LimitedGoogle Tag Manager, Google Analytics 4, Google AdsGordon House, Barrow Street, Dublin 4, IrelandData may be transferred to the USA; DPF
    Meta Platforms Ireland LimitedMeta PixelMerrion Road, Dublin 4, D04 X2K5, IrelandData 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).

  5. Security
    Data is processed over encrypted connections in access-protected systems, and only to the extent necessary for the purpose.

  6. 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 hello@adtracking.eu. I respond within one month at the latest.

  7. 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: ugyfelszolgalat@naih.hu
    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.

  8. 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 hello@adtracking.eu. 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 hello@adtracking.eu.
    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 hello@adtracking.eu. The person responsible for privacy is Boros Sámuel (hello@adtracking.eu). 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.

  9. Changes
    The Provider may amend this policy. The current version is always available on the website.