DRAFT — under legal review

Privacy Policy

Last updated: August 2026

1. Data Controller

Data controller: SuperSkiller.com ZRt., 1054 Budapest, Szabadság tér 7., Tax ID: 25561942-2-41, Company registration: 01-10-048848, Representative: István Kerek. Data processors: Képes Art Stúdió Kft., Everengine Kft. — they process data on our instructions.

2. Personal Data Processed

We collect and process the following personal data for the SkillPass.ID service: — Email address — Name (first and last name) — Phone number (optional) — Postal code (optional) — Billing data (optional) — Password (in encrypted form)

3. Legal Basis

The legal basis for processing is your consent (GDPR Art. 6(1)(a)). By registering, you explicitly consent to our data processing.

4. Your Rights

You have the following rights regarding your data: — Right to access: you can request to know what data we hold — Right to rectification: you can correct inaccurate data — Right to erasure: you can request deletion (right to be forgotten) — Right to data portability: you can receive your data in machine-readable format You can exercise these rights under Account → Data and Security, or by emailing [email protected]. If you are not satisfied with how we handle your data, you can lodge a complaint with the National Authority for Data Protection and Freedom of Information (NAIH, www.naih.hu).

5. Data Sharing

Your data is shared with: — Képes Art Stúdió Kft. — UI/UX and brand support — Everengine Kft. — infrastructure and backend services Otherwise, we do not share data with third parties unless required by law.

6. Retention Period

We retain data for as long as necessary. Inactive accounts (no login for 1+ year) may be deleted. Audit logs (data handling trails, including the security log of sign-ins, password and security changes) are kept for 180 days; at that point the security log's IP address, location data (city, region) and device identifier are anonymised, and the entries are then kept in archived backups.

7. Security

Data travels between your browser and our servers over HTTPS. Passwords are stored with the argon2 algorithm in a non-reversible (one-way hashed) form. The content of your personal store (vault) is encrypted in your browser (AES-256-GCM) before it is saved. Partner documents are stored with server-side encryption.