Privacy Policy
This privacy policy explains how Mersey Cloud Kft ("we", "us", "our") collects, uses, and protects personal data on fracsen.com.
We are committed to protecting your privacy in accordance with the EU General Data Protection Regulation (GDPR - Regulation 2016/679) and Hungarian data protection law (Act CXII of 2011).
Data Controller
| Company | Mersey Cloud Kft |
|---|---|
| Address | 6331 Foktő, Kisfoktő szállás 20., Hungary |
| hello@fracsen.com | |
| Tax number | 29314302-2-03 |
What Data We Collect
Analytics (Google Analytics 4)
If you accept cookies, we use Google Analytics 4 to collect pseudonymised usage data such as pages visited, time on site, device type, and approximate geographic location. This data helps us understand how our website is used and improve it.
- Legal basis: Consent (Art. 6(1)(a) GDPR)
- Data processor: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
- Retention: 14 months (Google Analytics default)
- Transfer: Data may be processed in the US under Google's Standard Contractual Clauses
If you decline cookies, no analytics data is collected.
Contact Information
When you contact us via the contact page or email, we process your name and email address to respond to your enquiry.
- Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) - responding to your enquiry
- Retention: Until the purpose of the correspondence is fulfilled, or up to 3 years for business relationship records
Fractional CTO: What My Agent Can See, and Where It Goes
The Fractional CTO engagement uses an AI agent that continuously follows whatever you choose to connect - Slack, email, Jira/Linear, GitHub, or however you already work - to produce digests that David reviews. This is separate from the website analytics and contact-form processing described above, and applies only to clients of that engagement.
- Access: Read-only wherever the connected tool supports it. You choose exactly what to connect - nothing is required, and access can be revoked at any time.
- What's processed: Messages, emails, code, and tickets from connected channels are processed to generate a digest for David to review and act on. Content is not used for any purpose beyond that engagement.
- Model provider (sub-processor): Anthropic (Claude) - processes engagement content to generate the digests David reviews, under terms where client data is not used to train any model.
- Retention: Engagement content is retained only as long as needed to produce and review digests, then deleted; exact retention is set out in the engagement proposal.
- Legal basis: Contract (Art. 6(1)(b) GDPR) - necessary to perform the Fractional CTO engagement.
A data processing agreement (DPA) covering this processing is available on request.
Your Rights
Under the GDPR, you have the right to:
- Access - request a copy of the personal data we hold about you
- Rectification - request correction of inaccurate data
- Erasure - request deletion of your personal data ("right to be forgotten")
- Restriction - request that we limit how we use your data
- Data portability - receive your data in a machine-readable format
- Object - object to processing based on legitimate interest
- Withdraw consent - withdraw analytics consent at any time using the "Cookie settings" link in the footer
To exercise any of these rights, contact us at hello@fracsen.com.
Data Security
This website is hosted on Amazon Web Services (AWS) infrastructure and delivered via Amazon CloudFront's global network. All traffic is encrypted via HTTPS (TLS). No personal data is stored in databases by this website - analytics is handled entirely by Google's infrastructure.
Third-Party Services
| Service | Purpose | Provider |
|---|---|---|
| Google Analytics 4 | Website analytics | Google Ireland Limited |
| Amazon CloudFront | Content delivery (CDN) | Amazon Web Services EMEA SARL |
| Amazon S3 | Website hosting | Amazon Web Services EMEA SARL |
| Cal.com | Call booking | Cal.com, Inc. |
| Anthropic (Claude) | AI processing (Fractional CTO engagements only) | Anthropic PBC |
Fonts
Typefaces (Newsreader, IBM Plex Mono) are self-hosted from our own AWS CloudFront distribution. No request is made to Google or any other third party to load fonts, and no visitor data leaves this list of providers for that purpose.
Supervisory Authority
If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Hungarian supervisory authority:
| Authority | Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) |
|---|---|
| Address | 1055 Budapest, Falk Miksa utca 9-11. |
| Website | naih.hu |
| Phone | +36 1 391 1400 |
Changes to This Policy
We may update this policy from time to time. Changes will be published on this page with an updated revision date.
Last updated: August 2026