ClickMate
Privacy Policy
1. Data Controller
The controller of personal data processed on the www.click-mate.hu website and in connection with ClickMate's services is Matcha Studio Kft. (represented by Krisztián Kosztolánszki), trading as ClickMate. Registered office: Máté utca 2, 1163 Budapest, Hungary. Company registration number: 01 09 435039. Tax number: 32365573-2-42. Email: info@click-mate.hu. Phone: +36 70 331 2587.
The controller is not required to appoint a data protection officer. For data protection matters, please contact info@click-mate.hu.
Personal data is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, "GDPR") and Hungarian Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information.
2. Overview of Processing Activities
Requesting a proposal on the website. When you fill in the enquiry form, we process your name, the name of your venue or company, your phone number and, if provided, your email address and message. The legal basis is taking steps prior to entering into a contract (Article 6(1)(b) GDPR) or, where you contact us on behalf of a business, our legitimate interest (Article 6(1)(f) GDPR). If no contract is concluded, we keep the data for 1 year from the last contact.
Contacting us by email or phone. We process your name, email address, phone number and the content of your enquiry, based on our legitimate interest in responding to it (Article 6(1)(f) GDPR). We keep the data for 1 year after the matter is closed.
Performing the contract. While performing a contract, we process the name, position, email address and phone number of the client's contact person, based on the performance of the contract or our legitimate interest (Article 6(1)(b) or (f) GDPR). We keep the data for 5 years after the contract ends, until the end of the civil law limitation period.
Invoicing. For invoicing, we process the name or company name, address, tax number and invoice details, to comply with a legal obligation (Article 6(1)(c) GDPR, under the Hungarian VAT Act and Accounting Act). We keep invoices for 8 years from the date of issue.
Analytics cookies. When we use Google Analytics 4, we process a shortened IP address, device and browser data, page views and events. The legal basis is your consent (Article 6(1)(a) GDPR and Section 155(4) of the Hungarian Electronic Communications Act). We keep the data until you withdraw your consent, for a maximum of [14] months.
Marketing cookies. When we use the Meta pixel and Google Ads, we process cookie identifiers, page views and events, also based on your consent (Article 6(1)(a) GDPR and Section 155(4) of the Hungarian Electronic Communications Act). We keep the data until you withdraw your consent, for a maximum of 13 months.
3. Proposal Requests and Enquiries
3.1. Purpose: to answer proposal requests (including requests for the free ad account audit) and other enquiries, to prepare proposals and to arrange appointments.
3.2. Source of the data: you provide the data yourself, through the form, by email or by phone. Your name, the name of your venue and your phone number are required to request a proposal; without them we cannot respond. Providing your email address and a message is optional.
3.3. Legitimate interest: where you contact us as the representative of a business, our legitimate interest is establishing a business relationship with that business. This interest is proportionate, because we only process the data needed to stay in contact, and you initiated the contact. You may object to this processing at any time.
3.4. Proposal requests are stored in the Wix system and in the controller's business mailbox. We do not use this data for newsletters or any other marketing purpose.
4. Contract Performance and Invoicing
4.1. While performing a contract, the controller processes the data of the client's contact person for communication, sending reports and arranging meetings.
4.2. Invoicing data is kept for the period required by law (8 years), under Hungarian Act CXXVII of 2007 on VAT and Section 169 of Act C of 2000 on Accounting.
4.3. Regarding data processed in the client's ad accounts during ad management (for example custom audience lists or lead ad data), the controller acts as the client's processor. That data is governed by the client's own privacy policy and the data processing agreement between the parties.
5. Cookies and Web Analytics
5.1. A cookie is a small text file stored on the visitor's device. When you first open the website, a cookie banner lets you choose which categories of cookies to allow. You can withdraw or change your consent at any time using the ["Cookie settings" link at the bottom of the website].
5.2. The website uses three types of cookies.
Strictly necessary cookies. These are set by Wix.com for the website to function, for security, for session management and to remember your cookie settings. The website cannot work without them, so they do not require consent.
Analytics cookies. We use Google Analytics 4 to measure website traffic and the number of proposal requests. These cookies are only loaded if you give your consent.
Marketing cookies. We use cookies from Meta Platforms (Meta pixel) and Google (Google Ads) to measure the effectiveness of our ads and to show remarketing ads. These cookies are also only loaded if you give your consent.
5.3. Refusing consent does not prevent you from using the website or requesting a proposal.
5.4. The full list of cookies and their expiry periods is available under "Settings" in the cookie banner. You can also delete or block cookies in your browser settings.
6. Processors and Recipients
The controller uses the processors listed below. Personal data is not disclosed to any other third party unless required by law or by an official request.
Wix.com Ltd. (40 Namal Tel Aviv St., Tel Aviv, Israel) provides website hosting and forms, and stores the enquiries received.
[Email provider, e.g. Google Ireland Ltd.] ([Gordon House, Barrow Street, Dublin 4, Ireland]) provides the business email account.
[Accountant's name] ([address]) provides accounting services and handles invoices.
[Invoicing software, e.g. Számlázz.hu / KBOSS.hu Kft.] ([address]) is used to issue invoices.
Google Ireland Ltd. (Gordon House, Barrow Street, Dublin 4, Ireland) provides Google Analytics 4 and Google Ads, if you give your consent.
Meta Platforms Ireland Ltd. (Merrion Road, Dublin 4, D04 X2K5, Ireland) provides the Meta pixel, if you give your consent.
7. Transfers to Third Countries
7.1. Wix.com Ltd. is based in Israel. The European Commission has adopted an adequacy decision for Israel, so transfers there are permitted under Article 45 of the GDPR without additional safeguards.
7.2. In the course of the processing carried out by Google and Meta, data may be transferred to the United States. These companies participate in the EU-U.S. Data Privacy Framework, for which the European Commission has adopted an adequacy decision, and they also apply the Standard Contractual Clauses (SCCs) approved by the Commission.
8. Data Security
The controller protects personal data with appropriate technical and organisational measures against unauthorised access, alteration, transfer, disclosure, deletion or destruction. The website is served over an encrypted (HTTPS) connection; the Wix account, the business email account and the ad accounts are protected by strong passwords and two-factor authentication; and only the controller and its processors have access to the data, to the extent necessary for their tasks.
In the event of a personal data breach, the controller acts in accordance with Articles 33–34 of the GDPR and, where required, notifies the Hungarian data protection authority (NAIH) within 72 hours.
9. Your Rights
You can exercise the following rights by writing to info@click-mate.hu. The controller responds without undue delay and within 1 month at the latest. Where justified, this deadline may be extended by a further 2 months, in which case we will inform you.
Right of access: you can ask whether we process your data, what data we hold, and request a copy.
Right to rectification: you can ask us to correct inaccurate data or complete incomplete data.
Right to erasure: you can ask us to delete your data if it is no longer needed, if you have withdrawn your consent, or if the processing is unlawful, unless the law requires us to keep it (for example invoices).
Right to restriction of processing: you can ask us only to store your data until a disputed matter is resolved.
Right to data portability: where processing is based on consent or a contract, you can request your data in a structured, machine-readable format.
Right to object: you can object at any time to processing based on legitimate interest.
Withdrawal of consent: where processing is based on consent (cookies), you can withdraw your consent at any time. This does not affect the lawfulness of processing before the withdrawal.
The controller does not carry out automated decision-making. Based on marketing cookies, Google and Meta may build an interest profile for advertising purposes, but only if you give your consent.
10. Remedies and Changes
10.1. If you believe that your data is being processed unlawfully, we recommend that you first contact the controller at info@click-mate.hu, so that we can resolve the complaint directly.
10.2. You may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH). Address: Falk Miksa utca 9–11, 1055 Budapest, Hungary. Postal address: 1363 Budapest, Pf. 9. Phone: +36 1 391 1400. Email: ugyfelszolgalat@naih.hu. Website: www.naih.hu.
10.3. If your rights are infringed, you may also bring the matter before a court. At your choice, you may file the claim with the regional court (törvényszék) competent for your place of residence or stay.
10.4. The controller reserves the right to amend this Privacy Policy. The amended policy enters into force upon publication on the website.
10.5. This Privacy Policy is also available in Hungarian. In case of any discrepancy between the language versions, the Hungarian version prevails.
Effective from: 1 January 2026.