Privacy Policy

Version 2.1 (English) · applies to vip.genmarketer.eu

Related documents: Terms and Conditions · Refund Policy and Right of Withdrawal · Imprint

About this version. This is the English-language version of the Hungarian Adatkezelési Tájékoztató and follows it in substance. It extends the version published at genmarketer.eu/privacy/ with the processing activities of the English shop and member area at vip.genmarketer.eu. Where a genuine discrepancy of meaning arises between the two versions, and you are a consumer, the interpretation more favourable to you applies.

1. Who processes your data?

Controller	Tibor Szántai, sole trader (egyéni vállalkozó)
Registered and postal address	Simon István utca 4/2, 4033 Debrecen, Hungary
Tax number	90986756-1-29
E-mail	info@genmarketer.hu
Website	https://genmarketer.hu/

Referred to below as the “Controller” or “GENmarketer”.

The Controller has not appointed a data protection officer, as the mandatory conditions under Article 37 GDPR are not currently met. Data protection questions and requests can be sent to info@genmarketer.hu.

2. What does this notice cover?

This notice covers processing on the following surfaces and services:

• https://vip.genmarketer.eu/ — the English shop, checkout, customer account and member area (this site);
• https://genmarketer.eu/;
• https://genmarketer.hu/;
• https://tudastar.genmarketer.hu/;
• https://ai-csapat.genmarketer.hu/;
• the GENmarketer Knowledge Base and Skill Hub;
• downloadable skills, prompts, knowledge bases, training courses and digital products;
• consulting, coaching and customer support;
• the GENmarketer Google Ads Connector;
• the GENmarketer Meta Ads Connector;
• connectors introduced later and named in this notice or an update to it.

Where GENmarketer processes a business user’s client data on that user’s documented instructions, the B2B data processing annex to the Terms also governs the relationship between the parties. For its own contractual, invoicing, security and legal enforcement purposes, GENmarketer acts as an independent controller.

3. Our principles

We process personal data only for specified, explicit and lawful purposes. We limit processing to the data and time necessary, grant access only in justified roles, and apply security measures proportionate to the risk.

We never ask for passwords, card data, API keys or OAuth tokens by e-mail. Please do not send such data in a support or feedback message either.

4. Individual processing activities

4.1. Opening the website and server logs

Data: IP address, date and time, requested URL, HTTP status, basic browser and device data, referring page, security events.
Purpose: serving the website, debugging, prevention of attack and abuse.
Legal basis: legitimate interest — secure and functioning operation of the website, Art. 6(1)(f) GDPR.
Retention: as a general rule max. 90 days; extracts relating to a security incident until the end of the legal claim or proceedings.

4.2. Registration and user account

Data: name, e-mail address, username, password hash, role, time of registration and last login, purchased entitlements, subscription and access status.
Purpose: account creation, authentication, product access and support.
Legal basis: performance of a contract, Art. 6(1)(b) GDPR.
Retention: for the life of the account, then as a general rule 30 days; evidence of purchase until the limitation of contractual claims.

Passwords are stored as a one-way hash, not in readable form.

4.3. Orders and contract

Data: name, e-mail, phone number if given, billing name and address, tax number, order identifier, product, price, discount, payment and fulfilment status, and the version and time of the Terms, privacy and digital-content statements accepted at checkout.
Purpose: ordering, contract, performance, withdrawal, guarantee and claim handling.
Legal basis: performance of a contract; for invoice data, legal obligation.
Retention: contractual data as a general rule 5 years; accounting documents and supporting data 8 years.

Providing this data is necessary in order to conclude the contract. Without the mandatory data the order cannot be fulfilled.

4.4. Subscriptions and recurring payments

Data: subscription identifier and status, product and billing period, start date, next renewal date, renewal and payment history, failed-payment and retry events, cancellation and its time, payment-method reference held at the payment provider (a token, not the card number), notification e-mails sent about renewals and price changes.
Purpose: operating the subscription, taking the recurring charge, giving and withdrawing access, notifying you about renewals, failed payments and price changes, and handling cancellations, refunds and disputes.
Legal basis: performance of a contract, Art. 6(1)(b) GDPR; legal obligation for accounting data; legitimate interest for fraud prevention and dispute evidence.
Retention: for the life of the subscription, then contractual data as a general rule 5 years and accounting data 8 years.

You can see and manage your subscription — including the next renewal date, the payment method and cancellation — in My account → Subscriptions.

4.5. Abandoned checkout recovery

Data: the e-mail address, name and contact data you enter at checkout, the contents of your cart, the time, and whether a reminder was sent, opened or clicked — recorded when you begin the checkout but do not complete the order.
Purpose: sending you a reminder that your order was not completed, and measuring whether that reminder worked.
Legal basis: pre-contractual step at your request and legitimate interest, Art. 6(1)(b) and (f) GDPR; where the applicable rules on electronic advertising require consent, we rely on consent, Art. 6(1)(a).
Retention: as a general rule 90 days from the abandoned checkout, or until you object or complete the order.

You can object at any time at info@genmarketer.hu, and every reminder e-mail contains an unsubscribe link. If you object, we delete the abandoned-checkout record and do not send further reminders.

4.6. Card payment

Card payments are provided by Stripe. GENmarketer does not receive the full card number or the security code.

Data: payer’s name and e-mail, billing data, amount, currency, transaction identifier, status, limited card characteristics, fraud-prevention signals, and — for subscriptions — the stored payment-method token used for renewals.
Purpose: payment, recurring charges, refunds, fraud prevention, accounting reconciliation.
Legal basis: performance of a contract, legal obligation, legitimate interest.
Retention: at GENmarketer according to contractual/accounting periods; at Stripe according to its own retention.

For some operations Stripe acts as a processor; for other purposes — in particular financial, regulatory and fraud-prevention purposes — it may act as an independent controller.

4.7. Invoicing

Data: billing name and address, tax number, e-mail, product, amount, invoice identifier and fulfilment data.
Purpose: issuing and delivering invoices, accounting and tax obligations.
Legal basis: legal obligation, Art. 6(1)(c) GDPR.
Retention: 8 years.

Invoicing is carried out through the Számlázz.hu system, with the involvement of KBOSS.hu Kft. (Záhony utca 7/D, 1031 Budapest, Hungary). Invoices for orders placed on this site are issued in English.

4.8. Knowledge Base, LearnDash and training progress

Data: account identifier, enrolment, entitlement, lessons viewed, progress, completion, downloads and technical events.
Purpose: digital access, showing progress, support and abuse prevention.
Legal basis: performance of a contract; legitimate interest for security events.
Retention: for the life of the access; after it ends as a general rule 30 days, minimum contractual evidence 5 years.

4.9. Contact, support and complaints

Data: name, e-mail, message, attachments, order data, reply and handling metadata.
Purpose: answering questions, technical assistance, handling complaints.
Legal basis: performance of a contract or pre-contractual step; legitimate interest; legal obligation for consumer complaints.
Retention: general enquiries max. 5 years; consumer complaints and replies 3 years.

4.10. Newsletter and direct marketing

Data: name, e-mail, source and time of subscription, version of consent, open and click data, unsubscribe.
Purpose: newsletters, offers and content communication.
Legal basis: consent, Art. 6(1)(a) GDPR; for electronic advertising, the applicable rules.
Retention: until unsubscribe or withdrawal of consent; evidence of consent and objection max. 5 years.

An unsubscribe link is available in every marketing e-mail, or you can request it at info@genmarketer.hu. We may keep an unsubscribed address on a minimal suppression list so that the objection continues to be honoured in future.

4.11. Skill Hub usage telemetry

Data: GENmarketer user identifier, channel, layer, connector, action, skill, redacted technical detail, timestamp, rate-limit events.
Purpose: performing the service, debugging, capacity, security, product quality.
Legal basis: performance of a contract and legitimate interest.
Retention: as long as necessary for the purpose; security records until the end of any claim.

4.12. Session and account-sharing risk signals

Data: pseudonymised session, device and network signals, concurrent-use and rate-limit events.
Purpose: enforcing seat limits and licence terms, preventing abuse.
Legal basis: legitimate interest.
Retention: short, proportionate to the purpose; incident records until the end of any claim.

A signal is never on its own a final decision — see section 10.

4.13. Feedback, contributions and automatic run outcomes

Data: the feedback or contribution you send, the skill and channel concerned, a content-free run outcome and, where the run did not succeed, a blocker code.
Purpose: improving the product and detecting degradation.
Legal basis: legitimate interest; consent where you send free-text content.
Retention: as long as necessary for product improvement.

4.14. Security events and legal claims

Data: security logs, incident records, evidence relating to a claim.
Purpose: protecting the service, establishing, exercising or defending legal claims.
Legal basis: legitimate interest; legal obligation where applicable.
Retention: until the end of the claim or proceedings.

5. Connectors

The GENmarketer Google Ads Connector and Meta Ads Connector access your own — or lawfully delegated — advertising accounts with your permission, to produce audits, reports and, where you have approved it, changes. The permissions requested, the inventory of platform data, how it is used and shared, and how to disconnect are described in detail in the connector chapters of the GENmarketer Privacy Notice, which apply unchanged to users of this site.

Google and Meta platform data obtained through a connector is used only to provide the service you asked for. It is not sold, not used for advertising to third parties, and not used to build a cross-customer database.

6. Cookies and similar technologies

This site sets the cookies necessary to operate the shop, the cart, the checkout and the logged-in customer account. Necessary cookies do not require consent. Measurement and marketing technologies described in section 7 are used on the basis described there.

7. Web analytics and measurement

7.1. Google Analytics and Google Ads measurement. We measure page views, sessions, checkout steps and purchases in order to understand how the shop performs. Cross-domain measurement between genmarketer.eu and vip.genmarketer.eu may be used so that one visit is not counted twice.

7.2. Meta Pixel and Meta Business Tools. May be used to measure the performance of advertising and to build advertising audiences.

7.3. Microsoft Clarity. May be used for aggregated behaviour analytics and session measurement, in order to find usability problems in the shop and checkout. Clarity is not used on surfaces directed at persons under eighteen.

7.4. Where the applicable rules require consent for a given technology, we collect it before that technology is loaded, and you can withdraw it at any time.

8. Recipients and service providers

Provider	Role and purpose	Place of processing / safeguard
Hostinger International Ltd. or the contracting Hostinger legal entity	hosting, database, servers, backups	EU and locations per the provider’s terms
Stripe Payments Europe, Limited, Stripe Technology Company, Limited and relevant Stripe entities	payment, recurring charges, fraud prevention, financial compliance	EEA and global infrastructure; DPA, SCCs or other lawful safeguard
KBOSS.hu Kft., Záhony utca 7/D, 1031 Budapest / Számlázz.hu	e-invoicing and delivery	Hungary/EEA
MailerLite Limited, 88 Harcourt Street, Dublin 2, Ireland	newsletter, subscriptions, automated e-mail	EEA; processor agreement
Google Ireland Limited, Google LLC and relevant Google entities	Analytics, Ads measurement, OAuth, Google Ads API and other Google services	EEA and third countries; controller/processor terms depending on service, DPF and/or SCCs
Meta Platforms Ireland Limited and relevant Meta entities	Pixel, page statistics, OAuth and Marketing API	EEA and global infrastructure; joint/independent controller or processor terms, DPF and/or SCCs
Microsoft Ireland Operations Limited and Microsoft Corporation	Clarity web analytics and session measurement	EU contracting party, US data centres possible; SCCs
the AI or client platform chosen by the user, e.g. Claude or ChatGPT	displaying prompts and connector results initiated by the user	per the platform’s own terms

Some WordPress, WooCommerce and LearnDash components run on our own hosting. If a licence, telemetry, cloud or support function transmits personal data to the vendor, this table must be extended before that function goes live.

An accountant, lawyer, IT contributor or authority may only receive data necessary for their task and legal basis.

9. International transfers

Some providers may process data outside the EEA, in particular in the United States. In such cases the transfer may be based on an adequacy decision of the European Commission — including the EU–US Data Privacy Framework where the recipient is certified; on standard contractual clauses adopted by the European Commission; or on a derogation under Article 49 GDPR, strictly on its own conditions.

Where necessary we apply supplementary technical and organisational measures. Further information about the applicable safeguard can be requested at info@genmarketer.hu.

10. Data security and automated decision-making

Proportionate to the risk, we apply in particular: TLS encryption in transit; role- and user-based access; hashing of passwords; restricted access to connector credentials and separation of secrets from source code; logical separation of customer and tenant data; minimal and redacted logging; pseudonymisation of session and abuse signals; backup, restore and updates; incident and vulnerability management; and periodic review of access rights.

We document any personal data breach. Where the breach is likely to result in a risk to the rights and freedoms of data subjects, we notify the supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of it. Where the risk is high we also inform the data subject, unless a statutory exception applies.

We do not take decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. The system may produce an account-sharing, rate-limit or security risk signal; this is not a final decision, and human review can be requested at info@genmarketer.hu before or after any substantive restriction — and immediately in the case of an urgent security measure.

11. Your rights

You have the right to request information and access; to request rectification of inaccurate data; to request erasure where there is no further legal basis; to request restriction of processing; to withdraw your consent at any time; to object to processing based on legitimate interest; to request data portability for automated processing based on contract or consent; to contest a significant decision based solely on automated processing; and to lodge a complaint and go to court.

Withdrawal of consent does not affect the lawfulness of processing carried out beforehand.

You can send your request to info@genmarketer.hu. To protect your identity and account we may ask for reasonable identification, but we never ask for a password or token. We respond without undue delay, as a general rule within one month; for complex or multiple requests the period may be extended by a further two months, of which we inform you within the first month.

12. Data deletion and severing connector connections

12.1. You may request in particular: deletion of your GENmarketer user account and profile; deletion of a connector connection, its tokens, the connected account list and stored connector data; deletion of all connector data; deletion of newsletter, feedback, abandoned-checkout or support data where there is no further legal basis; or rectification or deletion of a specific item of data identified by you.

12.2. Self-service disconnection. Where the feature is available, choose “Disconnect” in the connector settings. We then delete the active authentication data for that connector and the account list stored to operate the connection. You can also revoke access on the platform side — in your Google account under third-party apps and access settings, or in your Meta/Facebook account under Business Integrations. Platform-side revocation prevents further API access but does not necessarily delete reports or log entries previously stored lawfully at GENmarketer.

12.3. Deletion request by e-mail. Send your request to info@genmarketer.hu with the subject “Data deletion request”, giving the e-mail address associated with the account, what you are asking to be deleted, and — if known — the order or connector name. Do not send passwords, access tokens, API keys, card data or other secret authentication data.

12.4. What is not deleted immediately. Invoicing and accounting data must be retained for 8 years; contractual evidence, complaint records and security or claim-related records are retained for their own statutory or limitation periods. An unsubscribed e-mail address may be kept on a minimal suppression list so that your objection continues to be honoured.

12.5. Consequences of account deletion. Deleting the account ends access to the Knowledge Base, the Skill Hub and any active subscription. If you have an active paid subscription, cancel it first — see the Refund Policy.

13. Complaints and remedies

Please write to info@genmarketer.hu first, so that we can investigate the matter directly.

A complaint may be made to the Hungarian supervisory authority: Nemzeti Adatvédelmi és Információszabadság Hatóság (Hungarian National Authority for Data Protection and Freedom of Information) · Falk Miksa utca 9–11, 1055 Budapest, Hungary · postal address 1363 Budapest, Pf. 9 · e-mail ugyfelszolgalat@naih.hu · phone +36 1 391 1400 · naih.hu.

If you are resident in another EEA country, you may also lodge a complaint with the supervisory authority of your own country of residence or place of work. You may also go to court; where the statutory conditions are met you may bring proceedings before the court of your place of residence or stay.

14. Children

GENmarketer services are not designed for children. A person under eighteen may use a paid service only with the involvement of their legal representative. If we become aware that we are processing children’s data without a legal basis, we delete it.

15. Changes to this notice

We update this notice when there is new processing, or a change of provider, scope, law or technology. We give information about material changes affecting registered users through an appropriate channel, in advance where necessary. The version and effective date are shown at the top of the page. Earlier versions can be requested at info@genmarketer.hu.