Effective Date: 02.05.2026

1. Data Controller Information

Data Controller: AppWerk Kraft Kft.

Registered Office: 1036 Budapest, Lajos utca 125., Hungary

E-mail: info@appwerk.hu

Website: https://answertracker.app

The Data Controller processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and the applicable laws of Hungary.

2. Purpose of Data Processing

When using the AnswerTracker service, the Data Controller may process personal data for the following purposes:

  • Creating and managing user accounts;
  • Providing the service;
  • Customer support and communication;
  • Billing and subscription management;
  • System operation and security;
  • Statistical and analytical purposes;
  • Marketing communications and newsletter distribution;
  • Business communications.

3. Categories of Personal Data Processed

The following personal data may be processed in connection with the use of the service:

  • Name;
  • Company name;
  • E-mail address;
  • Telephone number;
  • Billing information;
  • IP address;
  • Login and usage logs;
  • Projects and keywords created by the user;
  • Technical and analytical data.

4. Legal Basis for Data Processing

The legal basis for processing personal data depends on the purpose of processing.

4.1. Performance of a Contract

Article 6(1)(b) GDPR

  • User registration;
  • Subscription management;
  • Provision of services;
  • Customer support.

4.2. Compliance with Legal Obligations

Article 6(1)(c) GDPR

  • Compliance with accounting and tax obligations.

4.3. Consent

Article 6(1)(a) GDPR

  • Sending newsletters;
  • Marketing communications directed to individuals;
  • Use of optional marketing cookies.

4.4. Legitimate Interest

Article 6(1)(f) GDPR

  • System security;
  • Fraud prevention;
  • Business communications;
  • Certain B2B communication activities where lawful based on a legitimate interest assessment.

5. Newsletters and Marketing Communications

5.1. Newsletter

Based on the user’s explicit consent, the Data Controller may send newsletters concerning:

  • Product updates;
  • Professional and educational content;
  • Events;
  • Promotions;
  • Service offers.

Consent may be withdrawn at any time through the unsubscribe link included in newsletters or by contacting info@appwerk.hu.

5.2. Business E-mail Communications

The Data Controller may send business-related informational e-mails to corporate contacts, including:

  • Information about services;
  • Professional materials and insights;
  • Webinars;
  • Market research;
  • Business offers.

When sending such communications, the Data Controller takes into account the recipient’s role, the existing business relationship, and provides a simple and free opt-out mechanism in every message.

Recipients may object to further communications at any time.

6. Data Processors

The Data Controller may engage data processors for the operation of the service, including but not limited to:

  • Hosting providers;
  • Cloud service providers;
  • Billing service providers;
  • E-mail service providers;
  • Analytics providers.

A current list of data processors is available upon request.

7. Data Retention Periods

  • User account data: for the duration of the account’s existence;
  • Billing and accounting data: 8 years;
  • Newsletter subscription data: until consent is withdrawn;
  • Marketing suppression lists (opt-out records): up to 5 years following the objection;
  • Log files: up to 12 months.

8. Data Subject Rights

Data subjects have the right to:

  • Request information about data processing;
  • Access their personal data;
  • Request correction of inaccurate data;
  • Request deletion of personal data;
  • Request restriction of processing;
  • Exercise the right to data portability;
  • Object to data processing;
  • Withdraw consent at any time.

9. Complaints and Legal Remedies

If a data subject believes that the processing of their personal data violates applicable laws, they may file a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH).

National Authority for Data Protection and Freedom of Information (NAIH)

Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary

Website: NAIH Official Website

Data subjects also have the right to seek judicial remedy before a competent court.

10. Amendments to this Privacy Policy

The Data Controller reserves the right to amend this Privacy Policy at any time.

Any amendments shall become effective upon publication on the website.