Privacy Policy

Effective Date: 1/28/2026

1. Data Controller Information

The data controller of the Application:

  • Name: Kiss-Hanzsa Produkciós Iroda Kft.
  • Tax ID: 24992141-2-06
  • Registered Office: Hungary

The data controller processes personal data in accordance with Hungarian laws, particularly the European Union General Data Protection Regulation (GDPR) and Hungarian data protection laws.

2. Types of Data Processed

The following data may be processed during the use of the Application:

2.1. Subscription Data

Subscription information processed through the Apple App Store and RevenueCat systems, which may include:

  • Subscription status
  • Subscription start and end dates
  • Payment information (handled by App Store)

2.2. Technical Data

Technical information necessary for the Application to function:

  • Device type and operating system version
  • Application version
  • Usage statistics (in anonymized form)

2.3. Notification Data

Device identifiers necessary for sending push notifications (in anonymized form).

2.4. Support Data

If the user contacts the operator through the Telegram channel, the shared information (name, messages) will be processed for the purpose of providing support.

3. Purposes and Legal Basis of Data Processing

3.1. Subscription Management

Purpose: Managing subscriptions, billing, and providing the service.

Legal Basis: Performance of a contract (GDPR Article 6(1)(b)).

3.2. Ensuring Application Functionality

Purpose: Ensuring the Application functions properly, fixing errors, implementing improvements.

Legal Basis: Legitimate interest (GDPR Article 6(1)(f)).

3.3. Sending Notifications

Purpose: Sending informational notifications to the user about changes in monetary indicators.

Legal Basis: Consent (GDPR Article 6(1)(a)), which can be withdrawn at any time.

3.4. Providing Support

Purpose: Answering user questions, resolving issues.

Legal Basis: Legitimate interest (GDPR Article 6(1)(f)).

4. Data Retention Period

The data controller stores data according to the following principles:

  • Subscription Data: In accordance with accounting laws, generally for 8 years after the subscription is terminated.
  • Technical Data: For a maximum of 2 years after the Application use ceases, or as long as necessary to provide the service.
  • Notification Data: As long as notifications are enabled, or until consent is withdrawn.
  • Support Data: For a maximum of 1 year after the support request is closed.

5. Method of Data Processing

The data controller processes data electronically and securely. To protect data, appropriate technical and organizational measures are implemented.

Subscription data is processed through the Apple App Store and RevenueCat systems, which have their own privacy policies.

6. Data Transfer, Data Processors

The data controller uses the following service providers as data processors:

  • Apple Inc.: App Store subscription management and billing. Apple's privacy policy: https://www.apple.com/privacy/
  • RevenueCat: Subscription management. RevenueCat's privacy policy: https://www.revenuecat.com/privacy

The data controller does not sell, rent, or transfer data to third parties except as listed above.

7. Data Subject Rights

The data subject (user) has the following rights:

  • Right of Access: May request information about whether their personal data is being processed, and if so, what data is involved.
  • Right to Rectification: May request correction of inaccurate data.
  • Right to Erasure: May request deletion of their data under certain conditions.
  • Right to Restriction of Processing: May request restriction of processing of their data in certain cases.
  • Right to Data Portability: May request transfer of their data in a structured, commonly used format.
  • Right to Object: May object to processing of their data in certain cases.
  • Right to Withdraw Consent: In case of consent-based data processing, may withdraw their consent at any time.

To exercise the above rights, the data subject may contact the data controller through the Telegram channel published in the Application.

8. Legal Enforcement

If the data subject believes that the data controller has violated data protection laws during data processing, they may file a complaint:

  • To the data controller through the Telegram channel published in the Application
  • To the National Authority for Data Protection and Freedom of Information (NAIH):
    Address: 1055 Budapest, Falk Miksa utca 9-11.
    Phone: +36 1 391 1400
    Email: ugyfelszolgalat@naih.hu
    Website: https://www.naih.hu

9. Automated Decision-Making

The Application does not perform automated decision-making, including profiling.

10. Modification of Privacy Policy

The data controller reserves the right to modify the Privacy Policy. Users will be notified of changes in the Application or by email. Continued use of the Application after publication of the modifications constitutes acceptance of the modified policy.

Last updated: 1/28/2026