Controller
SZHKP2026 Consulting Kft., 8192 Hajmáskér, Külterület hrsz 40/23., Hungary, company number 19-09-525950. For anything in this policy, write to [email protected].
What we collect
- Subscriber record: your email address, the name and address for the invoice, the timestamps recording that you accepted the terms and confirmed you are over 18, and which version of the terms that was. There is no account and no password.
- Emails: a record of which service emails we sent you and when. Not what they said.
- Payment: the amount, currency, plan, country and the billing details needed to issue a lawful invoice, and the state of your subscription. Card numbers never reach us. Stripe processes them and keeps the card on file for the subscription; we only ever see a reference and the last digits.
- Telegram: your Telegram user id and username, once you join the channel with your link, so we can take you out again when access ends.
- Free trial: the email address you start it with, when it starts and ends, and, so that it is taken once per person, a coded fingerprint of that address, of the Telegram account that joins and of the network address it was started from (for earlier card trials, also of the card, as Stripe identifies it). A fingerprint cannot be turned back into the address or account; it can only be matched against a new trial.
- Technical: your IP address, counted for up to a day when you ask for a new channel link or subscribe, to stop the forms being abused. Server logs record errors and can contain an IP or email address.
Measurement and advertising code runs only if you say yes when asked: Google Analytics, which counts visits, and the Meta pixel, which tells us which of our ads bring people here. Without a yes none of it loads and no cookie is set for you. If you agree, the service concerned receives your IP address, the public pages you open, plan choices, checkout starts, purchase amount, currency and an anonymous transaction reference, together with an identifier it keeps in a cookie. We do not send your email, invoice details, payment reference or private channel link as event data. You can change your answer at any time on the cookie page, which lists every cookie. The only other cookie is the one that keeps our own staff signed in to the admin pages.
Why, and on what legal basis
- To provide the service (access, channel membership, service emails): performance of our contract with you.
- To invoice and keep records: our legal obligations under Hungarian tax and accounting law.
- To keep the service secure and prevent abuse and payment fraud, including repeated free trials: our legitimate interests.
- Measurement and advertising cookies: your consent, given in the cookie question and withdrawn just as easily on the cookie page.
- Marketing emails: your consent, and nothing else. The box is never ticked for you, it is separate from accepting the terms, and refusing it changes nothing about buying or using the service. We record when you ticked it and the exact wording you were shown, so we can show what you agreed to. One click in any marketing email stops them for good, and we never email marketing to people who did not tick, even customers.
Who we share it with
Avanscript Kft. (9023 Győr, Csaba utca 21., Hungary) builds and runs the system for us, and has access to the data in it for that purpose.
Beyond that, only the providers that make the service work: Stripe for payments, where you also enter your billing address, Szamlazz.hu for invoicing, Telegram for the channel, Hetzner for hosting the site, its database and the mailbox our emails are sent from, Google for the mailbox that receives what you write to us, and Cloudflare, whose network every visit passes through and which therefore sees your IP address. If a page fails to load, your browser may also report the failure to Cloudflare. Each processes data on our instructions. We do not sell personal data and we never share it with bookmakers or advertisers.
If you agree to it in the cookie question, Google Ireland Limited receives data about your visit for measurement, and Meta Platforms Ireland Limited receives it for advertising. Either may process it in the United States.
Our server and database are in Germany. Where a provider transfers data outside the EU, that transfer relies on the European Commission's standard contractual clauses or an adequacy decision.
How long we keep it
- An unfinished subscription: if you fill in the form and do not complete the card page, what you typed is deleted after 30 days.
- Subscriber record: your email address, name, address and the record of emails we sent are deleted one year after your access ends. If you asked for our marketing email, the address alone stays until you unsubscribe. You can ask us to delete all of it sooner.
- Invoices and accounting records: eight years, because Hungarian law requires it. This is the one category we cannot delete on request.
- Counters that stop the forms being abused: one day.
- Free trial marks: two years from the trial, then deleted. They stay when the rest of your record is deleted, because their purpose is to recognise a second trial; they name nobody.
- Server logs: 30 days.
- Your cookie answer: remembered for 12 months, then you are asked again. The record that an answer was given, which holds a random reference and no address, is deleted a month after that.
- Backups: copies of the database are kept for 14 days, so anything deleted is gone from the backups two weeks later.
- Telegram id and username: deleted as soon as you leave the channel, whether your access ended or you left yourself. Only the coded trial mark above remains.
Your rights
You can ask for a copy of your data, correct it, delete it, restrict or object to processing, and take it elsewhere in a portable format. Withdrawing consent for marketing is one click in any marketing email, and it takes effect immediately with no confirmation step. Write to [email protected] and we will respond within one month.
If you think we have handled your data badly you can complain to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH), or to the supervisory authority where you live.
Security
There are no subscriber passwords to lose. Staff passwords are stored hashed and checked against known breach databases using a method that never sends the password anywhere. All traffic is encrypted in transit. Access to production data is limited to the people who need it.