Privacy notice
Controller
- Szolgáltató / Provider
- Digitalkey Kft.
- Székhely / Registered office
- 1154 Budapest, Dessewffy Arisztid utca 116.
- Adószám / Tax ID
- 13869346-2-42
- Cégjegyzékszám / Company registration
- 01-09-877478
- Nyilvántartó / Register authority
- [… / to be completed]
- tunelia@digitalkey.eu
- Telefon / Phone
- [… / to be completed]
- Tárhely / Hosting
- [… / to be completed]
This notice covers Tunelia's web service. Privacy enquiries and rights requests: tunelia@digitalkey.eu. We do not use the microphone for advertising or biometric identification.
Data, purposes, legal bases and retention
| Data and purpose | GDPR legal basis | Retention |
|---|---|---|
| Name, email, one-way password hash, account ID; account and sign-in | Article 6(1)(b), contract | While the account exists; legally required records are separated on a deletion request. |
| Vocal range and practice settings; requested personalisation | Article 6(1)(b) | In browser storage until cleared. |
| Assessment scores, target notes, matches, deviations and timestamps; history and recommendations | Article 6(1)(b) | Guest browser storage until cleared; account records while the account exists or until a deletion request. |
| Subscription, Stripe customer/transaction IDs, coupon redemptions, contractual acceptances; performance and accounting | Article 6(1)(b) and (c), legal obligation | As necessary for performance and legal claims; accounting records and supporting documents at least 8 years where Hungarian accounting rules apply. |
| Session, guest ID, abuse limits and technical logs; security and free allowance | Article 6(1)(f), legitimate interest in secure operation | Access tokens up to 30 days; reset tokens 30 minutes; security logs normally up to 90 days, longer until an incident is resolved; allowance identifiers as necessary for that function. |
| Support correspondence and consumer complaints | Article 6(1)(b), (c) or (f), depending on the matter | Complaint records and replies for the statutory 3 years; other correspondence as needed to resolve the matter and legal claims. |
Microphone and automated feedback
The microphone is accessed only with browser permission. Raw audio is processed locally in the browser; Tunelia does not record or upload audio recordings. Assessment scores and task data may be stored as described above. Automated scoring and recommendations are educational feedback with no legal or similarly significant effects. Stop the microphone at any time or revoke browser permission.
Recipients and international transfers
Hosting provider: [… / to be completed]. Email delivery: [… / to be completed]. Payment provider: Stripe, through the entity assigned to European customers under its current terms; Stripe may also act as an independent controller for payment, fraud-prevention and legal purposes. It receives necessary name, email, billing information and identifiers. Tunelia does not receive full card numbers or CVC codes. Accountants and authorities receive only information needed for their functions.
Stripe may process data outside the EEA; transfer safeguards, such as adequacy decisions or standard contractual clauses, are described in the Stripe privacy notice. The operator's final processor list identifies other processors' locations and transfer safeguards.
Your rights
You may request access, a copy, correction, erasure, restriction and, where applicable, portability. You may object to processing based on legitimate interests. Consent can be withdrawn for any separate processing based on consent; core account processing uses the legal bases above instead. We normally respond within one month and explain any necessary extension. Identity checks are proportionate. Mandatory retention may limit erasure.
You may complain to Hungary's National Authority for Data Protection and Freedom of Information (NAIH), or another competent EU authority, and seek judicial remedies. Current NAIH contact and submission channels: NAIH contact.
Security and choice
Passwords are stored as hashes and browser sessions use HttpOnly cookies. Subscription and assessment records require account authentication. Providing data is not itself a statutory obligation, but necessary data are required to provide accounts and paid access. We currently use no marketing trackers or newsletter subscription. This notice will be updated for new features or native applications.
Online withdrawal statement
We process the name, confirmation email, contract-identifying details and receipt time supplied in the statement to receive, confirm and handle the legal declaration (GDPR Article 6(1)(b) and (c)). Records are retained as necessary for handling the matter and legal claims; accounting records follow statutory retention. Confirmation is sent to the supplied address and support. No sign-in is required to submit a statement.