Cookie Policy

1. Introduction and Legal Background

Starlight Healings Kft. and Eszter Faragó Sole Proprietor (hereinafter: “Joint Controllers” or “Parties”) are committed to protecting the personal data of their website visitors. The purpose of this Cookie Policy is to provide clear, transparent information regarding the cookies used on this website, their purposes, categories, and management.

This policy is based on the following legislation:

• Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR)

• Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (Info Act)

   

• Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (E-Commerce Act)

   

• Act C of 2003 on Electronic Communications (Electronic Communications Act) – specifically Section 155

• Applicable recommendations and guidelines of the Hungarian National Authority for Data Protection and Freedom of Information (NAIH)

2. Joint Controller Clause and Cookie Notice

2.1. Identity of the Data Controllers and the Fact of Joint Control Regarding data processing activities carried out on this website and data collected via cookies placed through the site, the following legal entities/individuals act as Joint Controllers pursuant to Article 26 of the GDPR:

• Company Name: Starlight Healings Kft.

  • Registered Office: 2040 Budaörs, Levendula utca 14., Hungary

  • Company Registration Number: 13-09-244372

  • Tax Number: 32954283-2-13

  • Representative (Managing Director): Eszter Faragó

  • Email: info@backtoharmony.hu

• Sole Proprietor: Eszter Faragó e.v.

  • Registered Office: 2040 Budaörs, Levendula utca 14., Hungary

  • Registration Number: 60680385

  • Tax Number: 91215639-1-33

  • Email: info@backtoharmony.hu

2.2. Purpose, Legal Basis, and Allocation of Responsibilities in Joint Control The Joint Controllers jointly define the purposes and means of processing during the operation of their shared website. The division of tasks and responsibilities is structured as follows:

• Separation of Services: Starlight Healings Kft. handles contractual data processing (invoicing, order fulfillment) directly related to workshops, individual treatments, the Back to Harmony Club, and webshop sales. Eszter Faragó Sole Proprietor manages direct, individual contractual processing (invoicing, fulfillment) for Reiki Level 1 and 2 training courses.

• Website Traffic and Marketing Data: Website analytics, ad performance optimization, user experience enhancement, and technical maintenance (via cookies) serve the joint economic interest of both Parties; thus, the Parties act as joint controllers for data collected through these tools.

• Duty to Inform: Both Parties are jointly responsible for preparing, updating, and publishing this policy on the website.

2.3. Exercising Data Subject Rights (Visitors, Customers) As a website visitor or customer, you may exercise your GDPR-guaranteed rights (access, rectification, erasure, restriction of processing, data portability, and objection) via the shared contact email address above. Because both controller entities are represented by the same individual, your request will be evaluated and fulfilled across the databases of both entities in a single process within the statutory 30-day deadline.

2.4. Cookie Notice Supplement Data collected by cookies (analytical, marketing, and functional cookies such as Google Analytics or Meta Pixel) set in your browser upon visiting the website may be accessed by both Controllers for analytical and ad-targeting purposes. You may grant, customize, or decline your consent via the cookie banner (pop-up) displayed when the website first loads.

3. What Are Cookies?

A cookie is a small text file placed onto a user’s computer, smartphone, or other device by the visited website through the web browser. Cookies allow the website to recognize returning visitors, remember user preferences, and provide a tailored browsing experience.

Cookies do not directly contain personally identifiable details on their own (such as names or email addresses); however, when linked with other technical identifiers or data, they can constitute personal data, and their processing is therefore governed by the GDPR.

4. Types of Cookies Used on the Website

4.1. Strictly Necessary (Technical) Cookies These cookies are essential for the basic operation of the website. The site cannot function properly without them. They do not require user consent under e-commerce and telecommunications law, as they fall under statutory consent exceptions. The legal basis for processing is the Joint Controllers’ legitimate interest [Article 6(1)(f) GDPR] in ensuring the secure and smooth operation of the website.

4.2. Functional (Preference) Cookies

These cookies allow the website to remember choices you make (such as language preferences or font size). The legal basis is user consent [Article 6(1)(a) GDPR].

4.3. Statistical / Analytical Cookies

These cookies collect anonymous statistical information on website traffic and user engagement, allowing the Joint Controllers to improve site functionality and service delivery. The legal basis is user consent [Article 6(1)(a) GDPR].

Note: This website uses Google Analytics 4 (GA4), which may involve data transfers to the United States. Google LLC is certified under the EU–U.S. Data Privacy Framework, and standard contractual clauses (SCCs) approved by the European Commission are used as safeguards, consistent with the Controllers’ Privacy Policy. Further details: policies.google.com/privacy

4.4. Marketing / Targeted Advertising Cookies

These cookies track browsing habits, typically across multiple web properties. Using this data, providers build interest profiles to show tailored advertising and measure advertising campaign performance. These cookies originate from third-party services.

The sole legal basis for these cookies is the user’s prior, voluntary, specific, and informed consent [Article 6(1)(a) GDPR]. Marketing cookies are deployed only after consent is granted and will not be placed on your device beforehand.

Consent can be withdrawn at any time, free of charge, with future effect, via the cookie settings on our site or through your browser settings. Declining or withdrawing consent carries no negative consequences and does not affect the website’s core functionality.

These cookies originate from third parties; their data handling is governed by their respective privacy policies:

• Google LLC: https://policies.google.com/privacy

Deploying these cookies may involve data transfers to third countries (notably the United States). Adequate safeguards are primarily established via the EU–U.S. Data Privacy Framework (to which Google LLC is an active participant) and supplemented by European Commission Standard Contractual Clauses (SCCs). The use of marketing cookies involves profiling. Data subjects hold all GDPR-enshrined rights, including the rights to information, access, rectification, erasure, and the right to object to profiling.

5. Legal Basis for Cookie Processing

6. Managing Consent – The Cookie Banner

When first visiting the website, a cookie banner appears where the user can:

• Accept all cookies;

• Reject non-essential cookies;

• Customize settings by specific cookie category.

Strictly necessary cookies cannot be disabled via the cookie banner, as they are essential for operating the website.

Consent is voluntary, free of charge, revocable at any time, and is not a precondition for using the website. Withdrawing consent does not affect the lawfulness of processing carried out prior to withdrawal [Article 7(3) GDPR].

7. Managing and Disabling Cookies in Web Browsers

Users can modify cookie settings directly in their browsers. Cookie management instructions for popular browsers:

• Google Chrome: chrome://settings/cookies

• Mozilla Firefox: about:preferences#privacy

• Microsoft Edge: edge://settings/privacy

• Safari (macOS/iOS): Settings > Safari > Privacy & Security

Notice: Disabling cookies may cause certain features of the website to function incorrectly or become unavailable.

8. Data Subject Rights

8.1. Summary of Rights

Under Chapter III of the GDPR, you have the following rights:

• Right of Access (Article 15 GDPR): Request confirmation and details about your processed personal data.

• Right to Rectification (Article 16 GDPR): Request correction of inaccurate personal data.

• Right to Erasure (Article 17 GDPR): Request deletion of personal data (“right to be forgotten”).

• Right to Restriction of Processing (Article 18 GDPR).

• Right to Data Portability (Article 20 GDPR).

• Right to Object (Article 21 GDPR): Object to processing based on legitimate interests.

• Right to Withdraw Consent (Article 7(3) GDPR).

You may exercise your rights by writing to info@backtoharmony.hu. The Joint Controllers will process and respond to your request within 30 days (extendable by an additional 60 days in justified, complex cases).

8.2. Lodging a Complaint with the Supervisory Authority

If you believe that your personal data has been handled in violation of the GDPR, you may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):

• Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary

• Postal Address: 1363 Budapest, Pf. 9., Hungary

• Phone: +36 1 391 1400

• Email: ugyfelszolgalat@naih.hu

• Website: www.naih.hu

9. Data Security

The Joint Controllers implement appropriate technical and organizational measures to safeguard data processed via cookies, particularly to protect against unauthorized access, alteration, disclosure, or destruction [Article 32 GDPR].

10. Amendments to This Policy

The Joint Controllers reserve the right to amend this Cookie Policy unilaterally. Any updates will be published on the website, and renewed consent will be requested via the cookie banner where required by law. The current version will always remain accessible on the website.

11. Entry into Force

This Cookie Policy enters into force on June 19, 2026, and remains valid until revoked or replaced.

Budapest, June 19, 2026