This policy describes the processing of personal data related to the services provided by Comet-marketing Média Kft. (hereinafter: Service Provider / Data Controller), which operates the Galactica Code service, in accordance with the General Data Protection Regulation of the European Union (GDPR, 2016/679/EU) and the Hungarian Information Act (Act CXII of 2011).
1. The Data Controller
Name: Comet-marketing Média Kft.
Registered office: 2760 Nagykáta, Kázmér utca 22.
Company registration number: 13-09-209933
Tax number: 28991087-1-13
Email: hello@contact.galacticacode.com
2. Scope and Purposes of Data Processed
2.1 Registration and account management
- Data processed: name, email address, password (encrypted), time of registration
- Legal basis: GDPR Article 6(1)(b) — performance of a contract
- Retention period: until the account is deleted, then 30 days in backup
2.2 Astrological services
- Data processed: date, time, and place of birth (for astrological calculations)
- Legal basis: GDPR Article 6(1)(a) — consent
- Retention period: until consent is withdrawn
2.3 Dating feature (optional)
- Data processed: profile photos, bio, preferences, location (rounded), chat messages
- Legal basis: GDPR Article 6(1)(a) — consent
- Retention period: until the dating profile is deleted
2.4 Payment data
- We do NOT store card details. Payment is processed by Stripe Inc.
- We only receive the transaction ID and status.
- Retention period: 8 years in accordance with the Accounting Act
3. Data Processors (Third Parties)
- Stripe Inc. — card payment (USA, GDPR SCCs)
- Resend Inc. — transactional email delivery (USA, GDPR SCCs)
- OpenAI — text content processing (USA, GDPR SCCs). The data sent for processing is anonymous.
- Replit Inc. — hosting service (USA, GDPR SCCs)
4. Rights of Data Subjects
The data subject may at any time request:
- information about the processing concerning them (right of access)
- rectification of their data
- erasure of their data (“right to be forgotten”)
- restriction of processing
- portability of their data in a machine-readable format
- withdrawal of consent (this does not affect the lawfulness of processing prior to withdrawal)
These rights may be exercised at hello@contact.galacticacode.com. We respond to requests within 30 days.
5. Data Security
Passwords are encrypted with bcrypt. The connection is HTTPS (TLS 1.2+) encrypted. Authentication is performed with JWT tokens, with signature verification. The database has backups stored within the EU.
6. Complaints
The data subject may file a complaint with the NAIH (Hungarian National Authority for Data Protection and Freedom of Information; 1055 Budapest, Falk Miksa u. 9-11.; naih.hu), or may turn to a court.