V4 • English version • 28 September 2026
This is an English translation provided for convenience. The Hungarian version of this policy is the authoritative and always up-to-date version: https://mindclub.hu/adatkezelesi-tajekoztato/. In the event of any discrepancy between the two versions, the Hungarian version prevails.
This policy informs you about the cookies and related tracking technologies used on the mindclub.hu and booking.mindclub.hu websites. It describes their purpose, how long they operate, the providers who have access to the data, and your choices and legal remedies.
You decide whether analytics and marketing technologies are used. They are switched off by default; declining them does not prevent you from using the website or making a booking. You can change your choice at any time under “Cookie settings”.
1 The data controller and contact details
Data controller: SpARingbp Kft.
Registered office: 1022 Budapest, Bogár utca 2. A. ép. 1. em. 3. ajtó, Hungary
Company registration number: 01-09-442002
Tax number: 32776155-2-41
Contact person: Attila István Földi
Email: info@mindclub.hu
Phone: +36 30 698 8433
Direct URL of the Privacy Notice:
https://mindclub.hu/en/privacy-policy/
The detailed terms of processing booking data, payments, invoicing and email or SMS notifications are set out in the Privacy Notice. Consent to cookies does not constitute consent to newsletters or any other form of direct marketing.
2 What cookies and tracking mean
A cookie is a small file stored in your browser. It can, for example, remember your language choice or your cookie consent, or measure visits using an identifier. Session cookies remain on your device until the end of the session; persistent cookies remain for the stated period or until you delete them.
The protection is not limited to cookies: pixels, tracking links and other solutions that store data on, or read data from, your device may also fall within its scope. Server-side data transfers and the use of pseudonymised identifiers do not exclude the processing of personal data either.
3 Legal basis and your choice
The key provision of Hungarian law is Section 155(4) of Act C of 2003 on Electronic Communications (Eht.): storing data on a device, or accessing data stored there, requires consent based on prior, clear and comprehensive information that also covers the purpose. This rule must be read together with Article 5(3) of the ePrivacy Directive.
The exemption under the ePrivacy Directive applies only to operations necessary for transmitting a communication, or to storage or access strictly necessary to provide a service you have explicitly requested. Analytics and advertising measurement on this website do not fall within this exemption. Not using cookies does not in itself create an exemption.
Where we process personal data, the rules of the GDPR also apply. The legal basis for processing for analytics and marketing purposes is your consent under Article 6(1)(a) GDPR. The legal basis for processing related to necessary technologies, security and the storage of your settings is our legitimate interest under Article 6(1)(f) GDPR: secure operation and respecting your choice. Processing necessary to perform the booking and payment you requested is based on Article 6(1)(b).
The device-level exemption for necessary cookies and the GDPR legal basis for processing personal data are two separate questions. We do not switch on any analytics or marketing technology that requires prior consent by relying on legitimate interest.
A free choice for each purpose
Consent is voluntary, specific, informed and unambiguous. No analytics or marketing option is pre-selected. Silence, scrolling, continued browsing or closing the banner does not constitute consent. Analytics and marketing can be chosen separately; non-essential technologies can be declined with one click, just as easily as they can be accepted.
According to the Planet49 judgment (C-673/17), a pre-ticked box is not valid consent. The information provided must also cover how long cookies operate and whether third parties have access to them, regardless of whether the information stored on the device qualifies as personal data.
Storing and demonstrating your choice
The mc_consent_v1 cookie stores your choice for each category for up to 6 months on the .mindclub.hu domain, so the same decision applies to the main website and to the booking pages. If you use another browser or device, or delete the cookie, you may be asked to choose again. We will ask for your decision again if a new purpose is introduced or if there is a material change affecting your consent.
Under Article 7(1) GDPR, the controller must be able to demonstrate consent. The records kept for this purpose may not be used for advertising; the detailed terms of their processing and retention are set out in the Privacy Notice.
4 Cookies in use
Strictly necessary cookies
These cookies remember your choices, provide the function you requested and secure the payment. The necessity of Stripe’s security cookies relates to the payment process you requested; it does not authorise advertising or analytics tracking in general.
| Cookie and provider | Purpose and website | Duration |
|---|---|---|
| mc_consent_v1 SpARingbp Kft. | Stores your cookie choice; both websites, .mindclub.hu. | 6 months |
| wp-wpml_current_language SpARingbp Kft. / WPML | Remembers the chosen language (Hungarian or English) on the main website. | Session |
| __stripe_mid Stripe | Fraud prevention and payment security on the booking payment page. | 1 year* |
| __stripe_sid Stripe | Security and fraud prevention for the payment session. | 30 minutes* |
* Durations as published by Stripe. The payment provider’s cookie information is linked in section 9. The lifetime of a cookie is not the same as the retention period of payment data.
Analytics cookies
These operate only after you accept the Analytics category. The purpose of the processing is to understand, in statistical form, how the websites are visited and how visitors reach a booking; the legal basis is your consent.
| Cookie and provider | Purpose and data processed | Duration |
|---|---|---|
| _ga Google Ireland Ltd. | Distinguishes browsers using a random identifier; visit statistics on both websites. | 2 years |
| _ga_FLFB2DK2MX Google Ireland Ltd. | Stores visit and session data for GA4 measurement. | 2 years |
| mc_attr SpARingbp Kft. | Remembers the source of the visit from the main website through to the booking; utm_source, utm_medium, utm_campaign, utm_content, utm_term. Domain: .mindclub.hu. | 30 days |
Under this policy, mc_attr is used solely for statistical source measurement. Analytics consent does not permit its use for remarketing, advertising profiling or transfer to Meta or Google for advertising purposes; any such purpose requires separate marketing consent and prior information.
Cookies can be deleted before they expire. The retention of data already transferred to providers is a separate processing operation, so deleting cookies in your browser does not in itself end it.
5 Other and planned technologies
Tag management and fonts
Google Tag Manager manages the measurement tags; it does not set any cookies itself. This does not mean that loading it, or the services launched through it, involves no processing. Google Consent Mode v2 supports passing on your choices and does not replace consent. Before consent and after refusal, no data may be sent for analytics or marketing purposes, including cookieless measurement for such purposes.
How Google Fonts are loaded:
mindclub.hu and booking.mindclub.hu load their fonts (Oxanium, Exo) directly from the Google Fonts service, from fonts.googleapis.com and fonts.gstatic.com. In doing so, your browser connects to Google’s servers, and Google receives your IP address and the technical details of the request (for example the browser type and the address of the referring page). Google Fonts does not set cookies.
The purpose of this processing is to display the websites consistently and in line with the brand identity; the legal basis is our legitimate interest under Article 6(1)(f) GDPR. The data is received by Google Ireland Ltd.; Google may also process it outside the European Economic Area, including in the United States. This may take place on the basis of the European Commission’s adequacy decision on the EU–US Data Privacy Framework, or standard contractual clauses.
When fonts are loaded from an external source, the IP address and the technical details of the request may reach Google. The absence of cookies does not exempt this transfer from the rules on processing personal data.
Marketing tools not currently active
The tools below are planned. Listing them does not mean they are already in operation, and it does not constitute prior consent to their future use. Before introducing them, we will update this information and obtain valid marketing consent for the purpose concerned.
| Planned cookie | Provider and purpose | Planned duration |
|---|---|---|
| _fbp | Meta Platforms Ireland Ltd.; browser identification for measuring Facebook and Instagram ads. | 3 months |
| _fbc | Meta Platforms Ireland Ltd.; stores the identifier of an ad click. | 3 months |
| _gcl_au | Google Ireland Ltd.; links ad clicks to conversions. | 90 days |
Meta Conversions API
The planned Meta Conversions API would transmit data to Meta from our server when a booking is started or paid for: event data, the value in HUF, IP address, browser identifier, and the email address and phone number transformed using SHA-256. This transformation is pseudonymisation, not anonymisation; Meta may link the data to an existing account.
Conversions API data may be sent for marketing purposes only with prior marketing consent. After refusal or withdrawal, no further marketing events may be sent, including events generated from payment confirmations that arrive with a delay. This does not affect our own records required to fulfil the booking.
The WordPress editor cookies (wordpress_logged_in_*, wp-settings-*) and the mindclub_admin session cookie concern only logged-in staff; they are not set for ordinary visitors. The planned ClickSend SMS notification is not a cookie; the processing of booking messages is governed by the Privacy Notice.
6 Recipients and international data transfers
Data from our own cookies is processed by SpARingbp Kft. External providers may access the data transferred to them for the operation of their services. Setting a cookie on our own domain does not rule out the related measurement data reaching an external provider.
| Provider | Role in the processing |
|---|---|
| Google Ireland Ltd. | GA4 statistics and tag management; serving fonts (Google Fonts) on both websites. Google Ads is planned only. |
| Stripe Payments Europe Ltd. Ireland | Online payment, payment security and fraud prevention. Card details are entered directly into Stripe’s interface. |
| Hostinger | Hosting of booking.mindclub.hu; according to the available service description, on servers located in the EU. |
| [TO BE COMPLETED – name and identification details of the actual hosting provider of mindclub.hu] | Hosting of the main website, mindclub.hu. |
| Meta Platforms Ireland Ltd. | Planned Pixel and Conversions API; measurement of marketing events, only with appropriate consent. |
Whether a provider acts as a processor, an independent controller or a joint controller is determined by the service used and the relevant contract. The detailed roles, further recipients and retention periods are set out in the Privacy Notice; the providers’ own privacy information supplements this.
With international providers, access or data transfers outside the European Economic Area may also occur. This may only take place under conditions complying with Chapter V of the GDPR. An adequacy decision can only be relied on for recipients actually covered by it; otherwise, for example, standard contractual clauses and, where necessary, supplementary safeguards are required. Consent to cookies does not in itself replace the safeguards required for data transfers.
You can request information about the specific safeguard applied to a given recipient, and a copy of it, at info@mindclub.hu. Details for each provider and the countries concerned are set out in the Privacy Notice.
7 Withdrawal and deleting cookies
Using the “Cookie settings” control available on both websites, you can open the choice panel at any time, switch off the Analytics and Marketing categories, and save your decision. Withdrawal is free of charge and as easy as giving consent; it does not affect the lawfulness of processing carried out before withdrawal.
On withdrawal, further data collection and transfer for the purpose concerned stops. We remove the non-essential cookies concerned that are under our own control. We cannot always delete cookies stored on another provider’s domain directly for technical reasons; you can delete these in your browser’s privacy settings. Blocking necessary cookies may prevent certain functions, including payment.
8 Your rights and remedies
With regard to your personal data, under the conditions of the GDPR you may request access, rectification, erasure, restriction of processing and — for automated processing based on consent or contract — data portability. You may object, on grounds relating to your particular situation, to processing based on legitimate interest; in the case of direct marketing, the right to object is unconditional. You may withdraw your consent at any time.
You can send your request to info@mindclub.hu or to the postal address of our registered office. We will respond without undue delay and, as a rule, within one month; where necessary, we will inform you within that period of any extension under the GDPR and the reasons for it. If we cannot link a browser identifier to you, we may ask for additional identifying information needed to exercise your rights, only to the extent justified.
You may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) or bring the matter before a court. You do not need to complain to us first before starting proceedings with the authority.
NAIH
Registered office: 1055 Budapest, Falk Miksa utca 9–11., Hungary
Postal address: 1363 Budapest, Pf. 9.
Email: ugyfelszolgalat@naih.hu
Phone: +36 1 391 1400
Website: https://www.naih.hu
Online case submission: https://www.naih.hu/online-ugyinditas
9 Legal sources and further information
This policy is based on the GDPR, the ePrivacy Directive and the Eht., taking into account the Planet49 judgment, the technology-neutral approach of the EDPB and the practice of the NAIH regarding cookie consent. In line with the NAIH’s expectations, information must be specific, the choice free and consent demonstrable.
GDPR – Regulation (EU) 2016/679, in particular Articles 4, 5–7, 12–22 and 44–49
Eht. – Act C of 2003, Section 155(4)
ePrivacy – Directive 2002/58/EC, Article 5(3)
Planet49 – C-673/17, 1 October 2019, ECLI:EU:C:2019:801
EDPB – Guidelines 2/2023, final version
NAIH – Legal compliance of a website cookie consent framework, NAIH-3195/2022 (in Hungarian)
Provider information – Google Privacy Policy
Provider information – Stripe cookies and durations
Provider information – Meta Privacy Policy
We update this policy when our services or processing change. Before introducing a new purpose that requires consent, we will provide prior information and an appropriate choice; changing this policy does not in itself replace your consent.
The Hungarian version of this policy is the authoritative and always up-to-date version. The English translation may be updated later than the Hungarian version; in the event of any discrepancy, the Hungarian version prevails.