Privacy notice

2.1. Clicks on webshops' offers

The “Go to shop” button on a product page does not point at the webshop directly but at a redirect address on fittkereso.hu, which records the click and sends you on to the webshop’s page at once. Webshops pay for the visitors we send them, which is why we count clicks. No cookie is used for this.

Data

• the time of the click;
• which offer and product of which webshop was clicked, with the offer’s address, price, source and condition and the product’s category and brand at that moment;
• a pseudonymous visitor key;
• whether the click came from an automated program (a bot).

The visitor key

A cryptographic digest (HMAC-SHA256), made with a secret key only we know, of your IP address (its first 64 bits for an IPv6 address) and your browser’s identification string (User-Agent). The IP address and the User-Agent themselves are not stored. The key is erased 24 hours after the click; after that the click is linked to no one.

Purpose

• billing webshops per click;
• filtering repeat clicks: when the same visitor clicks the same product of the same webshop more than once within 24 hours, only one click is billed;
• filtering abuse such as automated, fraudulent clicks;
• aggregate statistics for webshops.

Legal basis

Legitimate interest under Article 6(1)(f) GDPR: our and the webshops’ interest in accurate billing free of abuse. The balancing test is available on request.

Retention

The visitor key for 24 hours. The rest of the click (without the key) for as long as billing needs it: [TO BE FILLED IN: retention period].

Recipients

Webshops see aggregate daily numbers only (clicks, billable clicks, products and offers clicked). They receive no data about any visitor.

Once you arrive on the webshop’s page, the webshop’s own data processing applies to you, as described in its own notice.

2.2. Partner portal accounts

The partner portal (fittkereso.hu/partner) is where the staff of webshops we have a contract with sign in.

Data

Name, e-mail address, role at the webshop (admin, writer, reader), time of the invitation and of the last sign-in, and when the e-mail address was confirmed. We store the password only as a salted, irreversible hash (scrypt); we never know it. To slow down password guessing, we store the number of consecutive failed sign-ins and the time of the last one. Signing in creates a session (when it was created, last used and when it expires); the browser gets only a random key to it in a cookie, of which we store only a hash. Of the one-time links in invitation, password reset and e-mail change messages we also store only a hash, for an e-mail change together with the new address.

Purpose

Signing in, managing access, protecting the accounts, showing the webshop’s data.

Legal basis

Performing the contract with the webshop (Article 6(1)(b) GDPR); for the webshop’s staff, the webshop’s and our legitimate interest in managing access (point (f)).

Retention

Until the account is deleted or the contract with the webshop ends: [TO BE FILLED IN: deletion deadline after the contract ends]. A session expires after 30 days without use, and at most 90 days after signing in; signing out deletes it at once, and a password change deletes the account’s other sessions. A one-time link is valid for 7 days in an invitation, 1 hour for a password reset and 24 hours for an e-mail change. Expired sessions and links are deleted within the hour, used links after 7 days.

2.3. System e-mails

The partner portal’s invitations and password resets are sent through Mailgun. Data: the recipient’s name and e-mail address and the message (including the webshop’s name and a one-time link). Legal basis and retention: as in 2.2; Mailgun keeps delivery logs for [TO BE FILLED IN: Mailgun’s log retention]. Section 2.9 covers the price alert e-mails.

2.4. Contacting us

You can write to us by e-mail or with the form on the Contact page. A message sent with the form reaches us as an e-mail: Mailgun delivers it to our mailbox, and our reply goes to the address you gave.

Data processed

• your name and e-mail address;
• your phone number, if you give it (optional);
• the message and whatever you tell us in it.

Purpose

Answering your message and dealing with the matter.

Legal basis

Our legitimate interest in answering enquiries (Article 6(1)(f) GDPR).

Retention

Until the matter is closed, or for as long as any claim may need it: [TO BE FILLED IN: how long messages are kept].

Spam protection

The form is protected from automated spam by Google reCAPTCHA (v3). Google’s script is loaded only once you start filling in the form; Google then sees your IP address and browser details, assesses your interactions with the page and sets the _GRECAPTCHA cookie. We decide from the score Google returns whether to pass the message on; the score is not stored. Legal basis: our legitimate interest in preventing abuse (Article 6(1)(f) GDPR). How Google processes data: Google Privacy Policy.

2.5. Serving the website

When you view the website, your browser connects to our hosting provider directly and loads product images from the Bunny CDN content delivery network; both see your IP address to do so. The hosting provider keeps server logs: [TO BE FILLED IN: what the host’s logs hold and for how long]. Legal basis: our legitimate interest in running the website securely (Article 6(1)(f) GDPR).

Visitor statistics. To see how many people visit the website, where they come from and which pages they view, we count page loads on our server, from the request your browser sends anyway when it opens a page. This uses no cookie and stores or reads nothing on your device, so it needs no consent (section 155(4) of the Eht.). Rejecting the statistics cookies (section 2.8) does not apply to this counting.

Data

• for each page load: the day, the page’s address (without its query), the referring website’s domain (when you came from another site), the link’s campaign tags (utm_source, utm_medium, utm_campaign) and the device type (phone, tablet or computer). Of these we store only aggregate counts, not linked to any visitor;
• a daily visitor identifier (see below), to count each day’s unique visitors. Partner portal pages, bots and moving between pages within the website are not counted.

The visitor identifier

A cryptographic digest (HMAC-SHA256) of your IP address (the first 64 bits of an IPv6 address), your browser’s identification string (User-Agent) and the day, made with a secret key only we know. We do not store the IP address or the User-Agent itself. As the day is part of it, the same visitor has unrelated identifiers on different days. The identifier is deleted within an hour after the day ends; only the day’s visitor count remains.

Purpose

Measuring the website’s traffic in aggregate: how many visitors it has each day, where they come from and which pages interest them.

Legal basis

Our legitimate interest in measuring and improving the website’s traffic (Article 6(1)(f) GDPR). The balancing test is available on request.

Retention

The visitor identifier until at most an hour after the day ends; the aggregate counts, which cannot be linked to a person, are kept as part of the statistics.

Recipients

Nobody; only we see the aggregate counts.

2.6. Saved recommendations

At the end of a finder (the E-bike finder, for example) you can save your answers under a name you choose. Product pages and product lists then show how well each product suits you. Unless you save them, we do not store your answers: they are only in the page’s address.

Data

• your answers to the finder’s questions: for example the kind of riding, the terrain, the distance, the budget and, if you gave them, your height (in centimetres) and your weight (as a range);
• the name you gave the recommendation;
• when it was saved and last used.

The identifier

When you save, we create a random key and keep it in a cookie (fk_finder) in your browser; our database holds only a cryptographic hash of it (SHA-256). No name, email address, IP address or browser data is stored with it, and no account belongs to it. A second cookie holding no secret (fk_finder_on) tells the pages that there is a saved recommendation.

The saved recommendation’s address

A saved recommendation’s address (URL) holds only a random identifier that cannot be guessed, not the answers. Anyone who gets the address can open the recommendation and its answers with it, so only send it to people you want to show it to. Once you delete the recommendation, the address no longer works.

Purpose

Showing how well products match your answers. We use them for nothing else.

Legal basis

Your consent (Article 6(1)(a) GDPR), given by pressing “Save” after the information shown before saving. You can withdraw it at any time by deleting your saved recommendations; this does not affect the lawfulness of the processing before.

Retention

6 months after the last use, unless you delete them sooner. The cookies also last 6 months and are renewed with every use.

Deletion

On the finder page, one by one or all at once with “Delete all my data”, which also deletes the cookies. If you delete the cookie in your browser, the data can no longer be reached and is deleted after the period above.

Recipients

Nobody, the shops included. Beyond computing the match we do not evaluate them, and no automated decision is made with them.

2.7. Cookies and local storage

We only use cookies that are strictly necessary or that remember a choice you made. The products you put in the comparison are kept in your browser’s local storage (localStorage) instead of a cookie: nothing is sent from there, only the comparison page’s address carries the products’ identifiers. Under section 155(4) of the Eht. none of these need consent. You can delete them in your browser’s settings at any time; your chosen appearance (light or dark) is then lost, and you have to sign in to the partner portal again. Details: Cookie settings.

2.9. Price alerts

On a product page, the “Price alert” button lets you ask us to e-mail you when the product’s lowest price falls to the target price you set, or lower. We check the prices once a day, from the webshops’ offers - including those of shops that have not agreed to be named. The alert starts only once you confirm your e-mail address (with the link in the confirmation e-mail). You need no account. The terms of the service are in the terms of use.

Data

• your e-mail address and the language of the e-mails;
• the product you watch, its condition (new), the target price and the product’s lowest price when you asked;
• when you asked, confirmed, were last alerted and reminded of the expiry, the last price you were alerted at, and when the alert expires;
• the version of this notice in force when you confirmed (the record of your consent);
• the cryptographic hash (SHA-256) of the random code in the confirmation link until you confirm, and how many confirmation e-mails went out that day (to limit misuse).

Purpose

Sending the price alerts you asked for and the e-mails that go with them (the confirmation, “alert set”, the expiry reminder). We use them for nothing else - no advertising, newsletters or profiling - and do not give them to the webshops.

Legal basis

Your consent (Article 6(1)(a) GDPR), given by opening the link in the confirmation e-mail and pressing “Confirm”, after the information shown when you ask for the alert. You may withdraw it at any time: unsubscribe in one click from any of our e-mails, delete your alerts on your price alerts page, or write to us. Withdrawing does not affect the lawfulness of the processing before it.

Retention

If you do not confirm your address, we delete it after 48 hours. A confirmed alert lives for 6 months from its confirmation or its last renewal; we send a reminder 7 days before it expires, and delete it when it does. If you unsubscribe, or delete all your alerts, we delete your address at once too. Mailgun’s delivery logs are covered in section 2.3.

Your price alerts page

Every e-mail of ours links to your price alerts page, where you can see, change, renew and delete your alerts, or delete your address and every alert at once with “Delete all my data”. The link carries an identifier signed with a secret key; whoever has it can reach your alerts, so do not forward our e-mails.

Spam protection

Price alert requests are protected by Google reCAPTCHA (v3) as described in section 2.4, in the same way and on the same legal basis; here too Google’s script loads only when you start filling in the form. We also limit the requests per browser, using a visitor key made as described in section 2.1, which we keep only in the server’s memory for at most one hour and never store.

Recipients

Mailgun delivers the e-mails (section 3). The webshops do not see who watches a product, and we give the data to nobody.