PRIVACY POLICY
INTRODUCTION
This Privacy Notice explains how we collect, use, store, and protect your personal data when you visit our website, browse it, or make a purchase (hereinafter: the “Service”). Coldbro Drinks Kft. acts as the data controller pursuant to the General Data Protection Regulation of the European Union (GDPR).
By using our Service, you acknowledge that you have read and understood this Notice and that you are aware of how your personal data is processe
Personal Data We Collect
We only collect data necessary for operating the webshop, fulfilling your order, or sending marketing communications you have requested.
a) Data You Provide
Name
Shipping and billing address
E-mail address
Phone number
Order information (purchased products, order number, delivery details)
Customer service messages
E-mail address provided for newsletter subscription (voluntary opt-in only)
b) Payment Data
We do not access or store your bank card or bank account details.
Payments are processed by Shopify Payments (Stripe), fully PCI-DSS compliant.
c) Automatically Collected Data
During browsing, we may automatically collect:
IP address
Browser type
Device type
Pages viewed
Time spent on the website
General, city-level (anonymized) location data
Cookies (see Section 10)
d) Cookies, Analytics, and Advertising Tracking
Our website may use the following tools:
Google Analytics
Google Ads remarketing
Meta Pixel (Facebook/Instagram)
TikTok Pixel
These tools may measure:
Pages visited
Products added to cart
Purchase value
Click behaviour
If a tool is not yet activated, it does not collect any data.
Purposes and Legal Bases of Data Processing
The GDPR requires all data processing to rely on a lawful basis. Coldbro Drinks Kft. processes personal data for the following purposes and legal grounds:
a) Order Fulfilment
Processing payments
Delivering packages (GLS)
Order confirmation
Legal basis: GDPR Art. 6(1)(b) – performance of a contract
b) Legal Obligations
Invoicing (Billingo.hu)
Accounting and statutory reporting
Legal basis: GDPR Art. 6(1)(c) – legal obligation
c) Customer Support
Managing emails and inquiries
Legal basis: Art. 6(1)(b) or (f) – legitimate interest
d) Marketing Communication and Newsletter
Only with voluntary subscription
Legal basis: Art. 6(1)(a) – consent
e) Advertising and Analytics (Retargeting)
Improving website performance
Displaying relevant ads (Google, Meta, TikTok)
Legal basis: Art. 6(1)(a) – consent
(Collected via cookie banner before any tracking begins.)
f) Security and Fraud Prevention
Ensuring transaction security
Detecting fraudulent activity
Legal basis: Art. 6(1)(f) – legitimate interest
Data Sharing
We only share data with trusted partners essential to the operation of the webshop:
a) WIX (webshop platform)
Processing browsing, transaction, and device data.
b) Stripe (payments)
Processing payment data.
c) Billingo.hu (invoicing)
Data processing according to Hungarian accounting laws.
d) GLS (delivery)
Name, phone number, shipping address / parcel locker details.
e) E-mail and Communication Services
WIX Email
Google Workspace
f) Advertising Platforms (in anonymized form)
Google (Analytics, Ads)
Meta (Instagram/Facebook)
TikTok Ads
We do not sell or rent personal data.
International Data Transfers
WIX, Google, Meta, TikTok, and Stripe may transfer data outside the EU (mainly to the USA).
Transfers are based on:
EU Standard Contractual Clauses (SCCs)
GDPR-required additional safeguards
Data Retention Periods
We retain data only for as long as necessary:
Order data: 5 years
Billing data: 8 years
Newsletter subscriptions: until unsubscribed
Customer service messages: 2 years
Analytics: tool-specific (Google Analytics default: 14 months)
Your Data Protection Rights (EU/GDPR)
You have the right to:
Access your personal data
Request correction
Request deletion (“right to be forgotten”)
Withdraw consent at any time
Object to data processing for marketing
Restrict processing
Request data portability
Lodge a complaint with the Hungarian Data Protection Authority (NAIH)
Requests may be submitted to:
Children
Our Services are not directed at individuals under 16, and we do not knowingly collect data from them.
Automated Decision-Making
We do not use automated decision-making that would have legal or significant effects on you.
(Remarketing tools operate only with cookie consent.)
Cookies
We use cookies for:
Website functionality
Cart and checkout operations
Performance improvements
Analytics and advertising (after consent)
A detailed cookie list is available via the WIX cookie banner.
Non-essential cookies can be disabled anytime in your browser settings.
Changes to This Notice
We may update this Privacy Notice from time to time. Changes will be indicated by updating the “Last Updated” date.
Contact
Coldbro Drinks Kft.
1088 Budapest, Szentkirályi utca 49., Hungary
hello@nakedcoffee.hu
Contact
Coldbro Drinks Kft.
Last updated: December 2025
Data Controller: Coldbro Drinks Kft.
Company Registration Number: 01-09-443371
Tax Number: 32801934-2-42
Registered Seat: 11088 Budapest, Szentkirályi utca 49. II. em. 12. ajtó, Hungary
E-mail: hello@nakedcoffee.hu