Privacy notice

Effective from 25 September 2026.

This notice explains how the operator of the cogma.hu website processes the personal data of visitors, enquirers and customers in accordance with the General Data Protection Regulation (GDPR, (EU) 2016/679) and Hungarian law (in particular the Infotv.).

1. The controller

Name: Tamás Molnár e.v. (sole proprietor; brand name: COGMA)
Registered office: 2120 Dunakeszi, Barátság útja 12. A ép. 3. em. 91. ajtó
Tax number: 92404777-1-33
Registration number: 62854746
E-mail: info@cogma.hu
Phone: +36 30 610 1751

Data protection requests (access, erasure, objection, etc.) are accepted at info@cogma.hu.

2. What data we process, why and for how long

2.1 Contacting us via the form or e-mail

Data: name, e-mail address, the text of your message, the package you are interested in, the state of the “coffee” checkbox and the language of the page; for e-mail enquiries, the data you provide.
Purpose: answering your enquiry, arranging a conversation, preparing a quote.
Legal basis: GDPR Article 6(1)(b) (steps taken at your request prior to entering into a contract); for other enquiries Article 6(1)(f) (legitimate interest in answering the enquiry).
Retention: until you request erasure. We review the data at least annually and delete what is no longer needed. If a contract is concluded, sections 2.5–2.6 also apply.
Recipients: the form message reaches us by e-mail (hosting provider: Rackhost Zrt.); the e-mail account uses Google's Gmail service.

2.2 Bot protection of the form (Cloudflare Turnstile)

Data: technical data (IP address, browser and device data, the result of the bot-protection check) processed by Cloudflare.
Purpose: protecting the form against automated abuse (spam).
Legal basis: GDPR Article 6(1)(f) (legitimate interest: security of the website and the form).
Recipient: Cloudflare, Inc. (USA); its own notice: cloudflare.com/privacypolicy. Transfers are covered in section 4.

2.3 Google Maps (only with your consent)

Data: when the map is loaded, your browser connects to Google's service (IP address, browser data, cookies).
Purpose: showing our registered office on a map.
Legal basis: GDPR Article 6(1)(a) (consent). The map only loads after you consent. You can withdraw consent at any time with the “Cookie settings” button in the footer; withdrawal does not affect the lawfulness of earlier processing.
Recipient: Google (Google Ireland Limited / Google LLC).

2.4 Booking a time and video calls (Google Calendar, Google Meet)

Data: if you click the “Let's video call – Book a time!” card, you are taken to a Google Calendar booking page (external site, opens in a new tab). The data you enter there: name, e-mail address, the booked time and any note; for video calls, the technical data of Google Meet.
Purpose: booking and holding the meeting.
Legal basis: GDPR Article 6(1)(b) (steps prior to entering into a contract) or Article 6(1)(f) (legitimate interest).
Retention: until you request erasure (see 2.1).
Recipient: Google; Google's own privacy notice also applies when you use the booking page.

2.5 Performing a contract and customer relations

Data: name, company name, e-mail address, phone number, address and billing details, communication about the project.
Purpose: delivering the service, keeping in touch.
Legal basis: GDPR Article 6(1)(b) (performance of a contract); Article 6(1)(f) for establishing or defending legal claims within the limitation period.
Retention: for the duration of the contract, then until the end of the general limitation period (5 years).

2.6 Invoicing and bookkeeping

Data: data on invoices (name, address, tax number, etc.).
Legal basis: GDPR Article 6(1)(c) (legal obligation: accounting and tax law).
Retention: for the statutory period applicable to accounting documents, typically 8 years.
Recipients: the provider of the invoicing software in use and the appointed accountant (their names are available on request).

2.7 Operating the website (server logs)

Data: when you open the site, technical logs may be created on the hosting provider's server (IP address, time, requested page, browser data).
Purpose: operational security, troubleshooting, preventing abuse.
Legal basis: GDPR Article 6(1)(f) (legitimate interest).
Processor: Rackhost Zrt., under its own rules (rackhost.hu/privacy-policy).
The website currently does not use any analytics, advertising or social-media tracking service.

2.8 Remembering your cookie choice

Your cookie choice is stored in your browser's local storage (localStorage); we do not receive it. This is storage necessary for the site to work, used to remember your choice.

3. Recipients and processors

Rackhost Zrt. (6722 Szeged, Tisza Lajos körút 41., Hungary): hosting and e-mail service.
Google (Google Ireland Limited / Google LLC): Gmail, Calendar, Meet, Maps.
Cloudflare, Inc.: bot protection of the form.
The provider of the invoicing software and the appointed accountant.

We do not pass your data to any other third party unless the law requires us to.

4. Transfers outside the European Economic Area

Google and Cloudflare are US providers, so your data may also be transferred to the United States. Such transfers rely on appropriate safeguards applied by the providers (for example the EU–US Data Privacy Framework or standard contractual clauses); details are in the providers' own notices.

5. Your rights

access to the data we hold about you (GDPR Article 15);
rectification (Article 16);
erasure (Article 17);
restriction of processing (Article 18);
data portability (Article 20);
objection to processing based on legitimate interest (Article 21);
withdrawal of consent at any time (Article 7(3)).

You can submit your request at info@cogma.hu. We respond within one month (which may be extended by two further months where necessary, given the complexity of the request).

6. Legal remedies

If you believe the processing of your data infringes your rights, you may lodge a complaint with the supervisory authority:

Authority: 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.)
Phone: +36 (1) 391-1400
E-mail: ugyfelszolgalat@naih.hu
Website: www.naih.hu

You may also take legal action; at your choice, the case can be brought before the regional court competent for your place of residence or stay.

7. Data security

We protect data with appropriate technical and organisational measures: the website is served over an encrypted (HTTPS) connection, the form is protected by bot protection, and the data is accessible to the controller.

8. Automated decision-making

We do not carry out automated decision-making or profiling.

9. Changes to this notice

We may update this notice from time to time; the current version is always available on this page. Last updated: 25 September 2026.