Privacy Policy

• Data controller: Prognovum System Kft.
• Registered office: 1114 Budapest, Orlay u. 3. mf. 3/A
• Company registration number: 01-09-983736
• Tax number: 23909986-2-43
• Professional contact: Bernáth Mihály Pál
• Email: info@appnova.hu

You can also reach the professional contact through the privacy email address. This is a contact role; we do not present it as an appointed data protection officer.

This policy covers the AppNova website, its project planners, contact forms, demos and measurement settings. Processing under a subsequent individual contract, invoicing or a completed customer application is separate from using this website and is covered by the privacy information for that process.

The demos use fictional participants and simulated business events. They do not redeem real coupons, take payments, post stock movements or collect camera or location data.

We process the information you enter, the summary of your requirements, technical identifiers needed for the process and submission status information. Measurement data is handled separately according to the purpose you have permitted.

Do not enter passwords, API keys, health information, confidential customer records or unnecessary information about other people. We do not automatically translate your free text when you switch languages.

We use contact and quotation enquiries to understand the task, respond and prepare the discussion you request. Without your name, email address and the business information marked as required in the form, we cannot process that enquiry. Your phone number is optional.

An enquiry is stored as a business record only after an explicit, valid and successful submission. Switching languages, completing a demo or transferring selected features into the planner does not send an enquiry. Required acknowledgement of the privacy information is not consent to analytics or marketing measurement.

reCAPTCHA spam protection — amendment, 2026-11-03

Final contact and project submissions use the Google reCAPTCHA Enterprise checkbox to prevent automated abuse. Google's code loads on the page containing the final submission form. Your browser connects directly to Google, which may process network, browser and verification interaction data. Our server sends only the verification token and public site key to the assessment API; it does not send your name, email address, phone number or project description.

This form security check is separate from marketing consent and works when optional measurement is declined. A failed check creates no enquiry, notification email or lead conversion. After an error, we ask for a new check and retain the entered fields. Technical logs contain only limited error categories, never the token or API key.

Provider processing is governed by the Google Cloud terms and Data Processing Addendum. The Google reCAPTCHA information describes its security purpose. See the Cookie Policy for browser storage. Amendment version: recaptcha-checkbox-v1-2026-11-03.

The planner keeps your current step and answers in the server-side session. The Hungarian and English versions share the same draft. Switching languages uses a validated save; if saving fails, the interface reports an error and does not claim that the transfer succeeded.

The preliminary summary uses rules to produce an initial commercial and technical classification. It is not a final quotation, credit assessment or automatic rejection of a customer; a person reviews the submitted enquiry. The planner does not automatically inspect a website address entered in the form. This process does not use a solely automated decision producing legal or similarly significant effects within GDPR Article 22.

After a successful submission, the application records a processing event and notification entries for the enquiry. The email queue holds a recipient, template, language, status and attempt timestamps. Test mode may produce a local email copy; it does not send external email.

The thank-you page and receipt are time-limited views bound to your own session, not public customer records. The downloadable app and website briefs are blank, static TXT outlines. Downloading one does not submit a document you later complete on your computer.

Responding to contact and quotation enquiries

• Data processed: Name, email address, company name and optional phone number; business task, notes, planner answers, summary, language, versions, submission time and status.
• Legal basis: GDPR Article 6(1)(b): steps taken at your request before entering into a contract.
• Retention: We retain an enquiry that does not lead to a contract for 90 days after it is closed. Review and erasure are manual procedures; the system does not erase enquiries automatically.

Continuing the project planning you request

• Data processed: Server-side session identifier, step, answers, revision and security nonce.
• Legal basis: GDPR Article 6(1)(b): steps taken at your request before entering into a contract.
• Retention: The draft expires after 120 minutes of inactivity or 24 hours after creation. The receipt is available in your own session for 120 minutes. Expiry does not mean every file is immediately physically erased.

Acknowledging and processing an enquiry

• Data processed: Recipient, email template and language, enquiry reference, delivery status, attempts and timestamps; an email copy in local testing.
• Legal basis: GDPR Article 6(1)(b): steps taken at your request before entering into a contract.
• Retention: We retain correspondence copies for 90 days after the related enquiry is closed and test copies for 30 days. They are erased through a manual procedure.

Security and abuse prevention

• Data processed: CSRF token, session binding, HMAC-based quota key, request timestamps and minimised error information. Infrastructure access logs may also contain IP addresses and request paths.
• Legal basis: GDPR Article 6(1)(f): the legitimate interest in keeping the website secure and preventing abuse, limited to necessary and proportionate processing.
• Retention: We retain inactive quota files for 7 days and security logs for 30 days. Expiry of a quota window does not delete the file itself; erasure is a manual procedure.

Remembering and withdrawing measurement choices

• Data processed: Random identifier, version, revision, choices for each measurement purpose, recording and expiry times, and withdrawal status.
• Legal basis: GDPR Article 6(1)(f): respecting and demonstrating your choice. The preference cookie is necessary; optional measurement requires separate consent.
• Retention: The preference cookie is valid for 180 days. We retain the server-side evidence of your choice for 180 days after expiry, then erase it manually. Expiry of the cookie does not itself erase the server-side evidence.

Optional analytics and advertising attribution

• Data processed: Allowlisted event, page and service identifier, campaign parameters, referring domain, consent-bound click identifier and subsequent business event. The adapters do not send form text.
• Legal basis: GDPR Article 6(1)(a): your consent to the specific measurement purpose, which you may withdraw.
• Retention: First-party attribution data is valid for 30 days and the delivery retention window is 90 days. Actual erasure uses a separately initiated cleanup procedure, not an automatic schedule. These windows do not determine an external provider’s own retention periods.

The legal basis for an enquiry or project planning does not extend to optional measurement. The security interest concerns protecting the website and forms, not advertising profiling. We rely on a legal obligation only where a specific obligation actually applies; we do not assign one general mandatory retention period to all website data.

The session cookie connects your browser to the server-side form process. The CSRF cookie helps prevent form submissions initiated from another website. Neither contains the complete form. Both are HttpOnly, use SameSite=Lax and have the Secure attribute when HTTPS is used.

Revisions, nonces, duplicate prevention and request quotas protect submissions. The quota key is derived using HMAC, rather than storing the IP address in plain text. The web server's own access logs may contain different information, including IP addresses and requested paths.

Optional purposes are denied by default. Analytics, Google advertising measurement, ChatGPT advertising measurement and Meta advertising measurement can be selected separately when that service is available in the environment. Choices are recorded by the server and their validity is checked again before sending data.

Declining consent does not prevent planning a project or contacting us. Saving a preference is neither a new enquiry nor an advertising conversion. Measurement checkboxes do not disable necessary operation or storage of your preferences.

• Service: Google Ireland Limited
• Purpose: Measuring page and service use, planner steps and demo events.
• Data processed: Allowlisted event, page and service identifier, campaign parameters, referring domain, consent-bound click identifier and subsequent business event. The adapters do not send form text.
• Legal basis: GDPR Article 6(1)(a): your consent to the specific measurement purpose, which you may withdraw.
• Retention: The Google Analytics 4 account's retention setting for user-level and event-level data is 14 months. This is not the lifetime of browser cookies and does not apply to standard aggregated reports. Our attribution data remains valid for 30 days and the retention window for delivery data is 90 days. Actual local erasure is performed by separately initiated cleanup, not an automatic schedule.
• Withdrawal: Can be withdrawn for each purpose in Measurement settings. Erasure of previously transferred data must be requested separately.

Demo measurement uses only allowlisted event and feature identifiers. It sends no sample images, fictional customer details, internal run identifiers, command logs or visitor free text. The adapter disables automatic page-view sending, Google Signals and the advertising personalisation signal. These application settings do not determine every aspect of the provider account's operation. Sending data to an external analytics provider requires both production activation and consent for analytics.

• Service: Google Ireland Limited
• Purpose: Attributing enquiries and subsequent qualified enquiries or contracts to Google advertising.
• Data processed: With consent: gclid, gbraid or wbraid, event identifier, conversion time and type; a HUF amount where relevant in a later offline export. No enhanced conversions or automatic collection of contact fields.
• Legal basis: GDPR Article 6(1)(a): your consent to the specific measurement purpose, which you may withdraw.
• Retention: Google Ads processes data necessary to operate the service according to Google's retention rules applicable to that service. Our attribution data remains valid for 30 days and the retention window for delivery data is 90 days. Actual local erasure is performed by separately initiated cleanup, not an automatic schedule. These windows do not determine Google's own retention periods.
• Withdrawal: Can be withdrawn for each purpose in Measurement settings. Erasure of previously transferred data must be requested separately.

An advertising click identifier may be linked to an event only with consent for that purpose. A subsequent business event recorded by a person may be included in a separate export; creating the export is not the same as uploading it to the provider. Existing enquiries are not automatically backfilled as advertising history.

• Service: OpenAI / ChatGPT Ads
• Purpose: Attributing enquiries and subsequent business events to ChatGPT advertising.
• Data processed: With consent: oppref, event identifier, timestamp, sanitised source URL, event type and service; a HUF amount for a contract event. The server adapter sends opt_out=true. The pixel has a separate verification gate.
• Legal basis: GDPR Article 6(1)(a): your consent to the specific measurement purpose, which you may withdraw.
• Retention: First-party attribution data is valid for 30 days and the delivery retention window is 90 days. Actual erasure uses a separately initiated cleanup procedure, not an automatic schedule. These windows do not determine an external provider’s own retention periods.
• Withdrawal: Can be withdrawn for each purpose in Measurement settings. Erasure of previously transferred data must be requested separately.

The website technically supports server-side conversion sending and a separately enabled browser pixel. The browser pixel operates only after production activation and separate OpenAI consent. The supported server-side data does not include names, email addresses or phone numbers. Technical support alone does not mean that the service is in use.

Meta Pixel — measurement amendment, 2026-10-16

Meta Pixel (ID: 1699334031384032) measures the effectiveness of Meta advertising. A page visit may send a PageView event; a successfully stored quotation or contact enquiry may send a Lead event. Invalid, interrupted or rejected submissions are not Leads, and reloading the thank-you page does not create another Lead.

The legal basis is your separate consent to “Meta advertising measurement” (GDPR Article 6(1)(a)). Previous Google or OpenAI choices do not authorise Meta. Neither the Meta library nor a JavaScript-free tracking image loads before consent.

Meta may receive the event type, a random page-view event identifier, page URL, browser and network details (including the IP address), and consented browser and advertising click identifiers. We do not pass submitted names, email addresses, phone numbers or form text to the Pixel. The integration disables automatic events and automatic configuration; it does not enable Advanced Matching.

The provider is Meta. The Meta Privacy Policy and Business Tools Terms describe services for EEA users and the role of Meta Platforms Ireland Limited. Processing may involve countries outside the EEA. Meta's terms govern provider retention and transfer safeguards; browser cookie lifetimes do not determine retention of all data held by Meta.

You can withdraw consent in Measurement settings at any time. Further sending stops, accessible _fbp and _fbc cookies are deleted, and the page may reload to remove the loaded SDK. Previously transferred data requires a separate erasure request. Amendment version: meta-pixel-v1-2026-10-16.

With consent, allowlisted campaign parameters and the referring external domain may be processed; the complete referring URL is not copied into our attribution record. The Cookie Policy explains cookies and the demo's session storage in more detail.

The URL determines the language. We do not create a language cookie or add personal information to localStorage merely to support switching languages.

Personnel with the access needed to handle your enquiry act on behalf of the controller. Service categories include hosting and infrastructure, backups, production email and, where separately activated and consented to, measurement providers.

• Name: Google / Google Workspace
• Task: Email service for the info@appnova.hu account.

• Name: Google Ireland Limited
• Task: Google Analytics 4: web analytics based on consent.
• Processing location: Ireland / EEA (contracting entity); processing locations are not restricted exclusively to the EEA.

• Name: Google Ireland Limited
• Task: Google Ads: conversion measurement and advertising attribution based on consent.
• Processing location: Ireland / EEA (contracting entity); processing locations are not restricted exclusively to the EEA.

Google Analytics, Google Ads, OpenAI / ChatGPT Ads and Meta Pixel are services the website technically supports. Technical support does not automatically give a provider access or cause data to be transferred.

We send data to Google Analytics and Google Ads only after consent for the relevant measurement purpose. The contracting entity for both services is Google Ireland Limited (Ireland, EEA). Google may also process data outside the EEA; we do not state that data physically remains exclusively within the EEA. Transfers are governed by Google's privacy and data processing terms applicable to the relevant service. Transfers outside the EEA rely on the appropriate transfer mechanisms applied by Google, including the European Commission's Standard Contractual Clauses (SCCs) where applicable. Recipients, destination countries and safeguards for any transfers outside the EEA by hosting, email and backup providers have not been verified. We therefore do not state that all website processing takes place within the EEA.

Google's terms and service classifications: data processing terms, controller-to-controller data protection terms, covered services. Google Analytics data retention documentation explains which data the account's configured retention period covers.

The professional contact acts on behalf of the controller to coordinate retention reviews and erasure requests.

We review retention manually every 30 days. This covers enquiries, related events, correspondence copies and optional data. When the retention period or processing purpose ends, an authorised person carries out or arranges erasure. We document any exception needed for a legal claim and review it regularly.

Backups are retained for 30 days. An authorised person arranges erasure of backup copies; the website does not provide automatic or immediate backup erasure. After a restore, we reapply previously completed erasures to the restored data.

You may ask whether we process your personal data and request access and a copy under the GDPR. You may request correction of inaccurate data and completion of incomplete data. Providing a copy must not adversely affect the rights of others.

You may request erasure where the conditions apply, for example when the data is no longer needed for its original purpose. You may also request restriction in the circumstances provided by the GDPR, such as while disputed accuracy is checked.

The rights available depend on the purpose and legal basis of the processing. Erasure is not unconditional: a demonstrated legal obligation or legal claim may require limited retention of relevant information. We explain any such exception and the available remedies individually. The system does not provide an automatic button that erases data from every store.

You may object to processing based on legitimate interests on grounds relating to your particular situation. The controller must then assess the conditions for continuing the processing. For consent-based measurement, the straightforward control is withdrawal for the relevant purpose.

Where processing is automated and based on consent or a contract, you may request the information you provided in a machine-readable format and, where technically feasible, its transmission under the GDPR. We do not promise an automatic export covering every data store.

You can reopen Measurement settings from the footer. Change each purpose separately or reject all optional measurement. Withdrawal does not affect the lawfulness of processing before it was withdrawn.

The system stops further sending for withdrawn purposes, removes relevant accessible provider storage and handles its own optional attribution data. Previously sent provider data and backups are not automatically erased by this action; you can request further action through our privacy contact.

Send requests to our privacy email address. After necessary and proportionate verification, we identify the relevant enquiry, events, correspondence copies, optional measurement data and backups. An authorised person manually carries out or arranges erasure or the required restriction and informs you of the outcome. Sending an erasure request does not itself delete data.

We inform you of action without undue delay and normally within one month. If an extension is necessary under the GDPR because of complexity or the number of requests, we explain it and the reason within the first month; the extension may be up to two further months. If we decline a request, we explain why and tell you about available remedies.

Initially, we ask only for the information needed to identify the relevant enquiry; do not automatically send a copy of an identity document. Exercising your rights is generally free of charge. Any exception permitted by the GDPR must be justified individually.

The Hungarian supervisory authority is:

Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)

You may complain to the authority and seek a judicial remedy. You may also contact another competent supervisory authority under the GDPR. You do not have to complain to us first in order to exercise these rights.

Implemented safeguards include session binding, CSRF protection, field validation, duplicate prevention, access and release gates, and consent checks for optional sending. Email and measurement test copies remain outside the public web directory. These measures are not an unlimited security guarantee.

For material changes, we update the policy version and actual effective date. A new measurement purpose or provider can be used only with the necessary information, consent and technical authorisation; changing this text alone does not enable data sending.

• Data controller: Prognovum System Kft.
• Registered office: 1114 Budapest, Orlay u. 3. mf. 3/A
• Company registration number: 01-09-983736
• Tax number: 23909986-2-43
• Professional contact: Bernáth Mihály Pál
• Email: info@appnova.hu

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