Privacy Policy (draft)
Controller: W System Hungary Kft., Harmat u. 208., 1108 Budapest, Hungary. Company registration number 01-09-470081, EU VAT HU33119856. Contact: [email protected].
What we process
- Business contact data: name, work email, agency, role. Collected from your enquiry, or from contact details your company publishes publicly (for outreach).
- Service data you send us: page URLs, page content, Google Search Console exports or read-only access (aggregate clicks, impressions, positions, queries). Search Console data normally contains no personal data of your site's visitors.
- Billing data if you become a customer (company details, VAT number, invoices; card data is handled by Stripe, not us).
- Website logs kept by our host (Cloudflare) for security. We use no tracking cookies or advertising pixels on this site.
Purposes and legal bases (GDPR Art. 6)
- Delivering pilots and paid refreshes and measuring results: contract or steps before a contract (6(1)(b)).
- Invoicing and bookkeeping: legal obligation under Hungarian accounting and VAT law (6(1)(c)).
- B2B outreach to publicly listed business contacts: legitimate interests (6(1)(f)). Outreach emails are written and sent by an AI agent ("Quinn") on behalf of W System Hungary Kft., and say so. Every message lets you opt out. Opt-outs are honoured within 1 working day and kept on a suppression list so you're not contacted again.
Processors
Google (Workspace email/docs), Cloudflare (hosting), Instantly (outreach email sending), Stripe (payments, if used), Billingo or Számlázz.hu (invoicing), and AI model providers used to produce drafts (page content and anonymous search data) and to write and answer outreach and support emails (business contact data and the content of that correspondence; no website-visitor data). This list is updated as services are added. Some processors are in the USA. Transfers rely on the EU–US Data Privacy Framework or Standard Contractual Clauses.
Retention
- Search Console data and page content: deleted within 90 days after the last measurement report, unless you ask us to keep it longer.
- Enquiries and outreach records without a contract: up to 24 months; suppression list (email only) kept as long as needed to honour your opt-out.
- Invoices and accounting records: 8 years (Hungarian Accounting Act).
Your rights
Access, rectification, erasure, restriction, portability and objection (including to outreach, at any time). Email [email protected]. You may complain to the Hungarian data protection authority (NAIH, naih.hu) or your local authority.
Draft. Have it reviewed before public traffic or outreach.