1. Who we are
- Controller
- Szabó Kevin egyéni vállalkozó (sole trader)
- Trade name
- Yera Labs
- Registered address
- Kossuth Lajos utca 79., 2161 Csomád, Hungary
- Register
- Hungarian Register of Sole Traders
- Registration number
- 61803204
- Tax number
- 91731298-1-33
- hello@yeralabs.com
- Phone and WhatsApp
- +36 30 402 8036
We have not appointed a Data Protection Officer, as none of the conditions in Article 37(1) GDPR apply to our activities.
2. Scope
This notice covers the yeralabs.com website, enquiries, online meetings, contracting and invoicing.
It does not cover personal data processed within the systems we build for clients. In those systems we act as a processor under a separate written data processing agreement with each client (Article 28 GDPR).
3. Our principles
We process personal data only for specified purposes and only to the extent and for as long as necessary (Article 5(1) GDPR). We do not sell your data. We do not send newsletters or marketing messages and we carry out no profiling or automated decision-making (Article 22 GDPR).
4. What we process and why
4.1. Contact form
Purpose: to reply to your enquiry, understand your needs and prepare a proposal.
Data: name, email address, phone number, company name (optional), your message, time of submission.
Legal basis:
- If you contact us as an individual or sole trader: steps taken at your request before entering into a contract (Article 6(1)(b) GDPR).
- If you contact us on behalf of a company: our legitimate interest (Article 6(1)(f) GDPR) in dealing with the company’s enquiry through its designated contact person. This does not unduly affect your rights, as we use only the details you provide and only to respond to the enquiry.
How it travels: the form is delivered by the Resend email service from its EU data centre to our hello@yeralabs.com mailbox (Google Workspace). Resend may keep delivered messages for a limited period under its own retention rules. Incoming emails are archived in Proton Drive. We do not store form submissions in any separate database.
Protection against abuse: To block spam and abuse, the form uses Cloudflare Turnstile. When you start filling in the form, Turnstile loads from Cloudflare’s servers and checks your IP address and technical characteristics of your browser (such as the browser type); it does not access what you type. Cloudflare also uses these signals as an independent controller to improve its bot detection. We check that your email domain accepts mail and look up its registration date in the public RDAP registry; for this, only the domain name (for example company.com) is sent to the public rdap.org lookup service. To prevent flooding, we keep a one-way hash of your IP address for 24 hours. If the form is abused, we keep the sender’s email address or domain on a blocklist for as long as the block is justified. Legal basis: our legitimate interest in protecting the form and our mailbox from abuse (Article 6(1)(f) GDPR).
Retention: 12 months from the close of the enquiry if no contract follows, then deleted. If a contract is concluded, section 4.4 applies.
Is it required? We cannot respond without your name, email address, phone number and message. The company name is optional.
4.2. Contacting us directly (email, phone, WhatsApp, LinkedIn)
Data: your name, contact details, the content of your message and when you sent it.
Purpose, legal basis and retention: as in section 4.1.
When you use WhatsApp or LinkedIn, WhatsApp Ireland Limited and LinkedIn Ireland Unlimited Company act as independent controllers under their own privacy policies.
4.3. Online meetings
Purpose: scoping your needs and discussing the project.
Data: name, email address, meeting time, and the image and voice of participants during the call.
Legal basis: as in section 4.1: Article 6(1)(b) for individuals and sole traders, Article 6(1)(f) for company contacts.
Meetings take place on Google Meet. We do not record them.
Retention: invitation details are kept for the periods set out in sections 4.1 or 4.4.
4.4. Contracts and ongoing contact
Purpose: concluding and performing the contract and communicating during the project.
Data: name or company name, address or registered office, tax number, the contact person’s name, email and phone number, and the identification data needed for electronic signature.
Legal basis:
- Where the contracting party is an individual or sole trader: performance of the contract (Article 6(1)(b) GDPR).
- For a contracting company’s contact person: our legitimate interest (Article 6(1)(f) GDPR) in the communication needed to perform the contract.
Electronic signature: contracts are signed through Signingo using DÁP (the Hungarian government’s digital identity app) for authentication. Signingo is operated by NP-Soft Studio Kft., which acts as an independent controller under its own privacy policy. The DÁP app is covered by its own privacy notice.
Retention: contracts are archived in Proton Drive and kept for 5 years after the contract ends. This is the general limitation period for contractual claims under section 6:22(1) of the Hungarian Civil Code, and keeping them is permitted by Article 17(3)(e) GDPR.
Is it required? Yes. Without this data no contract can be concluded.
4.5. Invoicing
Purpose: issuing invoices and meeting our invoice reporting and record-keeping obligations.
Data: billing name and address, tax number, invoice items and amount, and the email address used to send the invoice.
Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR) under Hungarian VAT, tax administration and accounting law: Act CXXVII of 2007, Act CL of 2017 and Act C of 2000.
Invoices are issued in Billingo. As required by law, invoice data is reported to the Hungarian Tax and Customs Administration’s Online Invoice system; Billingo submits this report on our behalf. Invoices are also archived in Proton Drive. Our bookkeeping is handled by an accountant.
Retention: 8 years (section 169(2) of the Accounting Act; section 78(3) of the Act on the Rules of Taxation).
4.6. Running and securing the website
Purpose: keeping the website available and fast and blocking attacks and abuse.
Data: IP address, browser and device type, time of request and page requested.
Legal basis: our legitimate interest (Article 6(1)(f) GDPR) in operating the website securely and reliably, which also protects visitors. We do not use this data to identify anyone or to build profiles.
The website runs on Cloudflare Pages. We keep no logs of our own. Cloudflare, Inc. processes the log data needed to provide its service as our processor for a limited period under its own data processing terms.
5. Cookies and local storage
We use no analytics, advertising or tracking tools. The site stores only what is strictly necessary for it to work. Under section 155(4) of the Hungarian Electronic Communications Act (Act C of 2003), which implements Article 5(3) of the ePrivacy Directive, this needs no consent, so we do not show a cookie banner.
| Name | Type | Provider | Purpose | Duration |
|---|---|---|---|---|
| __cf_bm | cookie | Cloudflare | filtering bot traffic | expires after 30 minutes of inactivity |
| cf_clearance | cookie | Cloudflare | records that you passed a security check; set only when a check is shown | while the check remains valid |
| yera-locale | local storage | Yera Labs | remembers your chosen language | until you clear it in your browser |
| cache | browser cache | your browser | loads images and files faster | per your browser settings |
The yera-locale value stays on your device and is never sent to us.
Links to ChatGPT, Claude, Perplexity, LinkedIn and WhatsApp open only when you click them. No data is sent to these services when the page loads.
The one exception is the contact form’s protection: when you start filling in the form, the Cloudflare Turnstile check loads from Cloudflare’s servers. See section 4.1.
If we introduce analytics or advertising tools in future, we will update this notice first and ask for your consent.
6. Who receives your data
Processors (acting on our behalf and on our instructions; Article 28 GDPR):
| Provider | Role |
|---|---|
| Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) | email and online meetings (Google Workspace, Google Meet) |
| Plus Five Five, Inc. - Resend (2261 Market Street #5039, San Francisco, CA 94114, USA) | delivering contact form messages |
| Proton AG (Route de la Galaise 32, 1228 Plan-les-Ouates, Switzerland) | archiving emails, contracts and invoices |
| Billingo Technologies Zrt. (Árbóc utca 6., 1133 Budapest, Hungary, company reg. no. 01-10-140802) | invoicing and invoice reporting |
| Cloudflare, Inc. (101 Townsend St., San Francisco, CA 94107, USA) | hosting and protecting the website |
| our accountant | bookkeeping |
Independent controllers (under their own privacy policies):
- NP-Soft Studio Kft. - Signingo (Ady Endre utca 106. 3. em. 13., 1204 Budapest, Hungary, company reg. no. 01-09-408557)
- WhatsApp Ireland Limited
- LinkedIn Ireland Unlimited Company
- Cloudflare, Inc. - use of Turnstile signals to improve bot detection (Turnstile Privacy Addendum)
Recipient by law: the Hungarian Tax and Customs Administration (invoice data).
The specialists we work with on projects have no access to enquiries or client data.
7. Transfers outside the European Economic Area
| Provider | Location | Safeguard |
|---|---|---|
| Cloudflare, Inc. | United States | Commission Implementing Decision (EU) 2023/1795 (EU-US Data Privacy Framework) and standard contractual clauses under Implementing Decision (EU) 2021/914 (Articles 45 and 46(2)(c) GDPR) |
| Resend | EU data centre; access from the United States is possible | standard contractual clauses under Implementing Decision (EU) 2021/914 (Article 46(2)(c) GDPR) |
| Proton AG | Switzerland | Commission adequacy decision 2000/518/EC, reaffirmed by the Commission on 15 January 2024 (Article 45 GDPR) |
| Google Ireland Limited | EEA; may transfer to sub-processors in the United States | Implementing Decision (EU) 2023/1795 and standard contractual clauses |
Billingo and Signingo are based in Hungary. You can request further details of these safeguards at hello@yeralabs.com.
8. Security
In line with Article 32 GDPR we apply technical and organisational measures proportionate to the risk:
- encrypted connections (HTTPS);
- access limited on a zero-trust basis to what each task requires;
- multi-factor authentication on administrative accounts;
- regular updates.
9. Personal data breaches
We investigate and record every breach (Article 33(5) GDPR). Where a breach is likely to result in a risk to people’s rights, we notify the supervisory authority without undue delay and, where feasible, within 72 hours (Article 33(1)). Where the risk is high, we also inform the people affected (Article 34).
10. Your rights
- Access (Article 15): you can ask whether we hold data about you, why, who receives it and how long we keep it, and obtain a copy.
- Rectification (Article 16): you can have inaccurate data corrected or incomplete data completed.
- Erasure (Article 17): you can ask us to delete your data. We will not delete data we must keep by law, such as invoices, or data needed to establish or defend legal claims.
- Restriction (Article 18): you can ask us to store your data without using it, for example while we check whether disputed data is accurate.
- Portability (Article 20): you can receive the data you gave us under a contract in a structured, machine-readable format, or have it sent to another controller.
- Objection (Article 21): you can object at any time to processing based on legitimate interest. We will then stop unless there are compelling legitimate grounds or the data is needed for legal claims.
- Withdrawing consent (Article 7(3)): where processing is based on consent, you can withdraw it at any time. This does not affect processing carried out before the withdrawal.
11. How we handle requests
Send your request to hello@yeralabs.com.
- Deadline: we respond within one month. For complex or numerous requests this may be extended by up to two further months; if so, we will tell you why within the first month (Article 12(3) GDPR).
- Cost: requests are free of charge. For manifestly unfounded or excessive requests we may charge a reasonable fee or refuse to act (Article 12(5)).
- Identity: if we have reasonable doubts about your identity, we may ask for additional information (Article 12(6)).
12. Complaints and remedies
You can lodge a complaint with the supervisory authority (Article 77 GDPR):
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Falk Miksa utca 9-11., 1055 Budapest, Hungary · Postal: 1363 Budapest, Pf. 9.
Phone: +36 1 391 1400 · Email: ugyfelszolgalat@naih.hu
You may also bring proceedings in court (Article 79 GDPR), including before the courts of the place where you live or are staying. If you live in another EU country, you can also complain to the data protection authority there.
13. Children
Our services are intended for businesses. We do not knowingly process the personal data of anyone under 18. If we become aware that we have, we will delete it without delay or restrict its use until it can be deleted.
14. Changes to this notice
We will update this notice whenever our services, tools or data processing change. The current version is always available on this website.
