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Privacy Policy

Effective: September 27, 2026  |  Version: 1.3

1. Introduction

adverr™ (hereinafter: the "Service Provider" or "we") is committed to protecting the personal data of its clients and partners. The purpose of this Privacy Policy is to inform you, in a transparent and easily understandable way, what personal data we collect, for what purpose and on what legal basis we process it, how long we store it, and what rights you have in connection with this processing.

Processing is carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), and with Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (the "Info Act").

2. Details of the Data Controller

  • Name: Novák Henriette, sole proprietor
  • Brand name: adverr
  • Registered office and postal address: 1203 Budapest, Közműhelytelep utca 26.
  • Registration number: 54907818 (Ministry of Interior, register of sole proprietors)
  • Tax number: 56272662-1-43
  • Email: info@adverr.hu
  • Phone: +36 30 845 0537
  • Website: https://adverr.hu

You can reach us directly at the contact details above with any privacy-related questions or requests.

3. Categories and Purpose of Data Processed

In connection with the adverr™ website and business activity, personal data may be processed in the following cases:

a) Requesting a quote
When you fill in the quote request form, we record your name, email address, telephone number and the description of your project. The purpose of this processing is to prepare the quote and make contact with you. We process this data until the contractual negotiations are concluded, or for 30 days from the withdrawal of the quote.

b) Booking an appointment
When you book a consultation appointment, we record your name, email address and information about the subject of the meeting. The purpose of this processing is to arrange and confirm the appointment. We retain this data for 30 days following the appointment, unless a subsequent business relationship requires longer retention.

c) Contacting us
For inquiries received through the contact form or by email, we process your name, email address and the content of your message. The retention period for this data is 1 year from the closure of the inquiry, for the purpose of asserting our legitimate interests.

d) Campaign Detective subscription and account analysis
Using the Campaign Detective service requires a user account. When you register, we record your email address and company name; your password is stored only in a non-reversible (hashed) form. To manage your subscription, we keep the customer and subscription identifiers received from the payment provider, together with the billed amount; we do not see or store any card data.

To run an analysis, you may, at your own discretion, connect your own Google Ads or Meta advertising account to the service. In that case, we store the access key and the identifier and name of the account, so that we can query the advertising data on your behalf. You can end this connection at any time in the service's interface. When you do, we delete the access key, we also revoke the access on Google's or Meta's side, and from that point on we no longer have access to your advertising account.

The analysis processes the following data from the advertising account: the advertising account's identifier, name, currency and time zone; the names and identifiers of campaigns and ad groups; the campaign's status, type, objective and budget, and for Meta campaigns also its start and end date; impressions, reach, frequency, clicks, click-through rate, cost per click and spend; for Google campaigns, the search impression share and how much of it was lost due to budget or ad rank; the number and value of conversion and purchase events; the naming and configuration of the conversion actions, and the auto-tagging setting; the policy status of the ads; the breakdown by placement; and, for Search Network campaigns, the search terms for which the ad appeared. We do not retrieve ad copy, keywords, targeting settings or audience lists.

A search term is the text someone typed into the search engine, so in exceptional cases it may contain personal data, for example if someone searched for their own name. We use these, too, solely for your analysis.

We store the completed analyses linked to your account, so that you can reopen them later. The data is stored encrypted, using the AES-256-GCM method, and only you have access to it.

Controller and processor roles. With respect to registration, subscription and billing data, we are the data controller. With respect to the data originating from your advertising account, however, you are the data controller, and we are the data processor acting on your instructions. The related terms, in accordance with Article 28 of the GDPR, are set out in Section 14.5 of the Terms of Service, which you accept when you place your order.

To prepare the analysis, we transmit the above advertising data to Google's Gemini language model. This includes the data originating from the advertising account, including the name and identifier of the advertising account. Your email address provided at registration, the company name you provided, your password, your payment data, and the access keys to your advertising accounts are not transmitted.

We use the paid tier of the Gemini service, under which the provider does not use the submitted data to develop its own products. Google logs the prompts and responses for a limited time, solely for detecting prohibited use and for disclosures required by law.

e) Website visits
When you visit the website, your IP address, browser type, the time of the visit and the subpages viewed are automatically recorded. We process this technical data solely for statistical purposes and to ensure the secure operation of the website. See Section 6 (Third Parties) and the Cookie Policy for details.

4. Legal Basis for Processing

The various processing activities rest on the following legal bases:

  • Consent (GDPR Article 6(1)(a)): Marketing communications, sending newsletters, placing cookies (for analytics and marketing purposes).
  • Performance of a contract (GDPR Article 6(1)(b)): Requesting a quote, preparing for the conclusion of a contract, providing the service to existing clients.
  • Legitimate interest (GDPR Article 6(1)(f)): Maintaining the security and integrity of the website, preventing abuse, handling inquiries. The pursuit of our legitimate interests is in every case proportionate to its effect of limiting the privacy of the data subject.
  • Compliance with a legal obligation (GDPR Article 6(1)(c)): Invoicing and bookkeeping obligations, complying with requests from authorities.

5. Data Storage and Security

The adverr™ website operates on the cloud platform of Vercel Inc. (440 N Barranca Ave #4133, Covina, CA 91723, USA). Vercel ensures an adequate level of protection for the data, including in the case of transfers outside the European Economic Area, on the basis of Standard Contractual Clauses (SCCs) and the EU-US Data Privacy Framework.

Our data security measures:

  • All data transmission takes place over TLS 1.2 or a higher encryption protocol (HTTPS).
  • Access to our systems is protected by strong passwords and two-factor authentication.
  • Only authorized staff members who are bound by confidentiality obligations may access personal data.
  • We carry out regular security reviews.

In the event of a personal data breach, we will notify the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) within 72 hours in accordance with Article 33 of the GDPR, and if the breach is likely to result in a high risk to data subjects, we will also inform the data subjects without undue delay.

6. Third Parties

Our website uses the following third-party services, which may also process personal data as independent controllers:

  • Google Analytics (Google LLC): For collecting website visit statistics. IP anonymization is enabled. Google's privacy notice is available at policies.google.com/privacy.
  • Meta Pixel (Meta Platforms Ireland Ltd.): For measuring conversions and optimizing remarketing advertisements. Meta's privacy notice is available at facebook.com/privacy/policy.
  • Google Ads (Google LLC): For measuring the results of our advertising campaigns. If you arrive by clicking on our ad, and then request a quote, book an appointment or purchase a subscription on the website, the system attributes this fact back to the ad. Google's privacy notice is available at policies.google.com/privacy.
  • Stripe (Stripe Payments Europe, Ltd.): For processing payments for the Campaign Detective subscription. Card data is handled directly by Stripe and never reaches us. Stripe's privacy notice is available at stripe.com/privacy.
  • Google Gemini (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA): For preparing Campaign Detective's analyses. We transmit the data of the examined advertising account to the model, as described in Section 3(d). We use the paid tier of the service, under which the submitted data is not used to develop the provider's own products. Google may process, transiently store or cache the data in any country where Google or its subprocessors maintain facilities. Transfers outside the European Economic Area take place, under Google's data processing terms, on the basis of the EU-US Data Privacy Framework (Google LLC is listed among the certified organizations) and of the standard contractual clauses adopted by the European Commission.
  • Vercel Inc.: Hosting provider. Technical logs of access to the site (IP address, timestamp) are recorded on Vercel's infrastructure to ensure secure operation.

Enhanced conversion measurement. When you purchase a subscription, we generate a one-way SHA-256 hash of the email address provided at checkout on our own server, and we transmit only this hash to Google Ads. The raw email address never reaches either the measurement code running in the browser or Google, and the original address cannot be reconstructed from the hash. Google matches the hash against its own signed-in users, which allows it to determine more precisely which ad led to the purchase. This takes place only if you have consented to advertising cookies. You can withdraw this consent at any time in the Cookie Settings, and after withdrawal we will no longer transmit the hash.

The processors used to operate Campaign Detective (Vercel Inc. and Google LLC) act under their own providers' data processing terms, which contain obligations in accordance with Article 28 of the GDPR. We will provide a list of these on request, and we will inform affected subscribers in advance of the engagement of any new processor.

We have described, step by step, how to delete your data and revoke access to your advertising accounts on the Data Deletion page.

7. Data Subject Rights

In accordance with the provisions of the GDPR, you have the following rights in relation to your personal data:

  • Right of access (GDPR Article 15): You may request information about what personal data of yours we process, its source, purpose and retention period.
  • Right to rectification (GDPR Article 16): You may request the immediate correction of inaccurate or incomplete personal data.
  • Right to erasure (GDPR Article 17): You may request the deletion of your personal data if the legal basis for processing has ceased to exist, the data is no longer needed, or you have withdrawn your consent.
  • Right to restriction of processing (GDPR Article 18): Under certain conditions, you may request that processing be restricted.
  • Right to data portability (GDPR Article 20): You may request data processed on the basis of consent or a contract in a machine-readable format, or request that it be transmitted to another controller.
  • Right to object (GDPR Article 21): You may object to processing based on legitimate interest. You may object unconditionally to processing carried out for direct marketing purposes.
  • Right to withdraw consent: For processing based on consent, you may withdraw your consent at any time, without any adverse consequence. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

You may submit your request in writing to info@adverr.hu. We will respond to your request within 30 days. In justified cases, this deadline may be extended by a further 60 days, of which we will inform you.

8. Cookies

Our website uses cookies to improve the user experience, ensure the website functions correctly, and for statistical and marketing purposes. You will find a detailed description of cookies, their types, lifespan and management options in our Cookie Policy. Placing analytics and marketing cookies requires your prior consent.

9. Data Retention Periods

We retain data only for as long as necessary:

  • Quote requests, contact inquiries: 1 year from the closure of contact.
  • Data of contractual clients: 5 years from termination of the contract (certain data for 8 years, under statutory accounting obligations).
  • Newsletter subscription: until consent is withdrawn.
  • Campaign Detective user account and analyses: for as long as the account exists. When the account is deleted, the associated analyses are also deleted.
  • Advertising account access key: until the connection is ended, or until the account is deleted.
  • Technical logs (IP address, visit data): 90 days.
  • Cookie lifespan: as set out in the Cookie Policy.

Once the retention period has expired, we irreversibly delete or anonymize the data.

10. Right to Lodge a Complaint (NAIH)

If you believe that the processing of your personal data infringes the provisions of the GDPR or the Info Act, you may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):

  • Postal address: 1363 Budapest, Pf. 9.
  • Email: ugyfelszolgalat@naih.hu
  • Website: www.naih.hu

However, we ask that you contact us directly before lodging a complaint, since our goal is to resolve any privacy-related issue quickly and effectively.

11. Changes

We reserve the right to amend this Privacy Policy. In the event of material changes, we will publish the amended notice on the website and will inform data subjects by email or another appropriate means. The effective date of any amendment will always be indicated in the header of the document.

12. Contact

Please feel free to contact us with any privacy-related questions or requests:

  • Email: info@adverr.hu
  • Phone: +36 30 845 0537
  • Website: https://adverr.hu
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Service provider: Novák Henriette e.v. (sole proprietor) · Közműhelytelep utca 26., 1203 Budapest, Hungary · Registration number: 54907818 · Tax number: 56272662-1-43 · info@adverr.hu · +36 30 845 0537

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