Privacy Policy

frombach.net is designed to keep data collection to a minimum. This Privacy Policy explains what data is processed when you use this site, why, and what rights you have under the General Data Protection Regulation (GDPR) and other applicable privacy law.

1. Who I Am

This website, frombach.net, is operated by Zoltan Frombach, a freelance software developer registered as a sole proprietor (egyéni vállalkozó) in Hungary and working from Budapest. Zoltan Frombach is also the name under which I do business. I am the data controller for the personal data described in this policy. If you have questions about this Privacy Policy or data protection, please use the Contact page or email zoltan@frombach.net . My full business details are in Section 2 of the Terms of Use .

2. What This Website Does

frombach.net presents the freelance software development and server administration services I offer and lets you contact me about them. There are no user accounts, no online store, and no sign-up forms. Apart from the contact form described below, you can use this site without providing any personal data.

3. Cookies and Tracking

This website does not use cookies for analytics, advertising, or personalization. I do not use tracking pixels or user profiling technologies.

No cookie consent banner is displayed because no non-essential cookies are set by this website itself. Strictly necessary technical cookies or similar mechanisms may be used by Cloudflare’s bot-protection feature on the contact page. See Section 5 below for details.

4. Contact Form and Email

If you use the contact form (or email me directly), the information you send, such as your name, email address, the topic you select, and your message, is processed for the purpose of receiving and responding to your inquiry.

Legal basis (GDPR): Legitimate interests (Article 6(1)(f)), responding to a message you have voluntarily sent to me, and, where your message is about a possible project, taking steps at your request before entering into a contract (Article 6(1)(b)).
Retention: Contact form submissions are sent to me by email and are not intentionally stored in a website database. Emails may be retained for as long as reasonably necessary to handle your inquiry and any follow-up.
Use: Your contact data is used only to review and respond to your message. It is not sold, added to any marketing list, or used for profiling. Except for the technical signals Cloudflare receives during the contact form’s bot protection (see Section 5), it is not shared with third parties.

5. Cloudflare Turnstile (Bot Protection)

This website uses Cloudflare Turnstile on the contact form to protect against automated spam and abusive submissions. Turnstile is a privacy-preserving bot-detection solution provided by Cloudflare, Inc., and it is loaded only on the contact page.

Legal basis (GDPR): Legitimate interests (Article 6(1)(f)), protecting the contact form from spam and abuse, and ensuring the integrity of the site.
Technical data processed: When you interact with the contact form, Turnstile may process certain technical data on Cloudflare’s systems in order to distinguish human users from bots, including your IP address, TLS fingerprint, user-agent header (browser and device identifier), and origin data related to the site. Under GDPR case law and guidance from data protection authorities such as NAIH, an IP address qualifies as personal data even when it does not directly identify a specific individual. Turnstile does not transmit the data you type into the contact form, such as your name, email address, or message, to Cloudflare.
Strictly necessary cookies: Turnstile or related Cloudflare features may set strictly necessary security cookies or use similar technical mechanisms as part of bot detection. These are strictly necessary for security purposes and are exempt from consent requirements under the ePrivacy Directive and applicable national law.
Data controller: This processing is carried out by Cloudflare, not by me directly. I am the data controller for contact form submissions, but Cloudflare acts as an independent controller or processor for the Turnstile-related technical data, under its own privacy policy.
Cloudflare’s privacy documentation: Cloudflare Turnstile Privacy Policy | Cloudflare Privacy Policy

6. Infrastructure and Technical Processing

Like any website, frombach.net is delivered through hosting and network infrastructure. Technical data such as IP addresses, HTTP request headers, and temporary server logs may be processed by the infrastructure provider for the purposes of delivering the site, maintaining reliability, and protecting against abuse. This processing is limited to what is technically necessary for site operation. Server logs are retained for a maximum of 30 days, after which they are automatically deleted.

7. External Links

This website links to third-party sites, such as GitHub. If you follow a link to another website, that website may use cookies or similar technologies under its own privacy and cookie policies. I do not control third-party cookies or tracking that occurs after you leave this site, and you should review the privacy policy of any third-party service before interacting with it.

8. Data Transfers

Cloudflare is a US-based company, which may transfer the technical data it processes for Turnstile, excluding the data you type into the contact form, to the United States or other countries for processing. Cloudflare states that it relies on appropriate legal mechanisms, including Standard Contractual Clauses, for international transfers of personal data from the EEA. Please refer to Cloudflare’s privacy documentation for current information on transfer safeguards.

If you are in the European Economic Area (EEA), United Kingdom, or another jurisdiction with applicable data protection law, you may have the following rights:

Right of access: to request information about personal data I hold about you
Right to rectification: to request correction of inaccurate personal data
Right to erasure: to request deletion of personal data in certain circumstances
Right to restriction: to request that processing be limited in certain circumstances
Right to data portability: to receive, in a structured, machine-readable format, the data processed on a contractual legal basis by automated means
Right to object: to object to processing based on legitimate interests
Right to lodge a complaint: with your national data protection supervisory authority (in Hungary, the National Authority for Data Protection and Freedom of Information, NAIH)

Because this website does not maintain user accounts, browsing profiles, or marketing databases, the personal data I hold is limited to contact form submissions and email correspondence, plus technical infrastructure logs. The practical scope of some rights may be limited as a result.

To exercise your rights or ask questions about your data, please use the Contact page. I will respond to your request within one month, in line with GDPR Article 12.

If you believe your personal data is being processed unlawfully, you can complain to the Hungarian supervisory authority, the National Authority for Data Protection and Freedom of Information (NAIH), 1055 Budapest, Falk Miksa utca 9–11., postal address 1363 Budapest, Pf. 9., phone +36 1 391-1400 , email ugyfelszolgalat@naih.hu , website naih.hu . You may also bring the matter before a court (GDPR Article 79).

10. Children’s Data

This website offers freelance software development and server administration services and is not directed at anyone under the age of 16. I do not knowingly collect data from anyone under 16. If you believe a minor has provided personal data through the contact form, please let me know via the Contact page or zoltan@frombach.net , and I will delete it promptly.

11. Changes to This Policy

This Privacy Policy may be updated from time to time to reflect changes in the site, infrastructure, or legal requirements. The latest version will always be published on this page with an updated date at the top.

This Privacy Policy is available in English and Hungarian. If the two versions differ, the Hungarian version prevails.