Privacy
policy

Please note: this is a courtesy translation. In any question of interpretation the Hungarian version is the legally binding one.

Please read this privacy policy (hereinafter the Policy) carefully. It describes our practices regarding the processing of your personal data under the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679 of the European Parliament and of the Council).

This Policy applies to persons using the Controller's services (you). It sets out how the Controller collects, uses and processes your personal data and provides information about data subject rights. The Controller is committed to the protection and security of personal data. Personal data is always processed lawfully, fairly and transparently.

The Controller's responsibility and contact details

• Controller: Artúr Lukács, sole trader
• Registered address: Arany János utca 13, 9151 Abda, Hungary
• Phone: +36 30 584 8024
• Email: info@media-stratos.com
• Website: https://stratosweb.hu
• Tax number: 91381611-2-28
• Activity: website production, web design, online marketing and digital services

Purposes of processing

The Controller processes personal data for the following purposes:

• enabling contact
• preparing quotes and client communication
• receiving and recording newsletter requests
• performing services
• operating and developing the website
• statistical and analytical purposes

Categories of personal data processed

When contacting us or requesting a quote

• name
• email address
• phone number
• company name (if provided)
• any other information given in the message
• the device identification string your browser sends (user agent)
• a salted, irreversible fingerprint of the IP address — the IP address itself is not stored

When the project questionnaire is completed

• the above, and the answers given in the questionnaire

With every submission

• which page the submission was sent from, and which page was landed on first
• the domain name of the referring website (without the full referring address)
• the campaign labels in the link (utm_source, utm_medium, utm_campaign, utm_content, utm_term), if there are any
• how long the form took to fill in, and the screen orientation

The campaign labels come only from the five parameters above: every other value in the link is ignored. We do not read or store advertising click identifiers (such as gclid or fbclid). These values stay in your browser's session storage until you close the tab, and reach us only if you actually submit a form.

When subscribing to the newsletter

• email address

We record newsletter requests, but no newsletter system is running at present: signing up does not trigger a confirmation email, and no newsletter is sent. Your request stays on record until you ask us to delete it.

Retention periods

• contact data: no more than 5 years
• newsletter data: until consent is withdrawn
• invoicing data: 8 years (under the Hungarian Accounting Act)

Data transfers and processors

The Controller transfers personal data only to the extent necessary to provide the service, on the basis of a legal obligation, or with consent.

Processors

• Hosting provider: Netlify, Inc. — 101 2nd Street, San Francisco, CA 94105, United States. Service: serving the website and running the server-side functions (Netlify Functions) that receive form submissions.
• Database provider: Supabase Pte. Ltd. — 65 Chulia Street #38-02/03, OCBC Centre, Singapore 049513. Service: storing the enquiries received through the forms and supporting the private Portal.
• Email provider: the provider of the Controller's own mail system. The website itself sends no email; the Controller replies to enquiries from their own mailbox.
• Google Ireland Ltd. — Gordon House, Barrow Street, Dublin 4, Ireland. Service: Google Analytics 4 audience measurement, only where the visitor has explicitly consented. Without consent Google Analytics is not loaded and no data reaches Google.

Google Search Console is not audience measurement and not a data processor: it reports how our own site appears in search, and does not track visitors. The website uses no Meta Pixel and no other social-media tracking code. The social icons in the footer are ordinary links and load nothing.

Use of cookies

By default the website sets no cookies. Cookies are set only by audience measurement, and only where the visitor has explicitly consented in the bar shown at the bottom of the page. Without consent, measurement does not start, no cookie is placed on the device, and no data whatsoever is transmitted to Google.

The website uses no advertising, marketing or profiling cookies. Google Analytics advertising features (Google Signals, ad personalisation) are switched off.

Which cookies may be on your device

• Analytics cookies (Google Analytics 4) — only after consent. The cookies named _ga and _ga_<identifier> distinguish returning visits and sessions. They contain no name, email address or phone number.
• Remembering your choice — the decision is kept in the browser’s local storage (stratos.consent). This is not a cookie and never reaches the server; it exists solely so that, after a refusal, you are not asked again on every page.

What we measure, and what we do not

Measurement covers which pages are read, how far into them visitors get, and which buttons they click. The data sent for measurement never includes a name, email address, phone number, company name, text typed into a form, questionnaire answers, or the identifier of an enquiry or submission. This is not merely policy: before sending, the measurement code checks the field names and discards, in its entirety, any event containing a prohibited field.

Withdrawing consent

Consent can be withdrawn at any time, exactly as easily as it was given: the Cookie settings button in the footer reopens the choice so it can be changed. On withdrawal, measurement stops immediately and the website deletes any _ga cookies already set. Cookies can also be deleted or blocked at any time in the browser’s own settings.

Refusing consent does not restrict use of the website in any way: the site works in full without measurement.

Data subject rights

The data subject has the right:

• to request information about the processing
• to access their own data
• to request their rectification
• to request their erasure (“right to be forgotten”)
• to request restriction of processing
• to object to the processing
• to exercise the right to data portability

Legal remedies

In case of a complaint, the data subject may turn to the Hungarian National Authority for Data Protection and Freedom of Information:

NAIH
Falk Miksa utca 9–11, 1055 Budapest, Hungary
https://naih.hu
ugyfelszolgalat@naih.hu

Definitions

• Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
• Processing: any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means — for example collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, restriction, erasure or destruction.
• Transfer: making personal data processed by the Controller accessible to third parties.
• Personal data breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data processed.
• Identifiable natural person: one who can be identified, directly or indirectly, by reference to an identifier.
• Recipient: a natural or legal person, public authority, agency or other body to which personal data is disclosed.
• Consent of the data subject: a freely given, specific, informed and unambiguous indication of the data subject's wishes.
• Data subject: a natural person identified or identifiable on the basis of any information.
• Users: visitors to the websites operated by the Controller.
• Third party: anyone other than the data subject, the controller or the processor.
• Personal data: any information relating to the data subject.

Final provisions

The Controller reserves the right to amend this Policy. Amendments take effect on publication on the website.