PRIVACY POLICY
Last updated: September 22, 2026
DATA CONTROLLER
Primal Risk Manager is operated by:
Péter Berzlánovich, sole proprietor
Registered office: Kisrókás utca 28., 9724 Lukácsháza, Hungary
Registration number: 62836661
Tax number: 92393842-1-38
Email: bp.business.trading@gmail.com
For questions regarding the processing of personal data, please contact us at the email address above.
PERSONAL DATA WE PROCESS
Depending on how you interact with our website and services, we may process:
• Name and email address
• Contact information you provide to us
• Information submitted through our free-course signup form
• Purchase and transaction-related information
• Technical information such as IP address, browser type, device information and website usage data
• Information contained in communications you send to us
Payment card details are processed by the payment and commerce providers used for purchases and are not stored by Primal Risk Manager.
PURPOSES AND LEGAL BASES
We process personal data for the following purposes:
Website operation and security
Legal basis: legitimate interests and, where applicable, consent.
Responding to enquiries and providing customer support
Legal basis: taking steps at your request and legitimate interests.
Processing purchases and providing purchased digital products
Legal basis: performance of a contract and compliance with legal obligations.
Accounting, tax and legal record-keeping
Legal basis: compliance with legal obligations.
Sending the free Risk Management Guide and related email communications
Legal basis: consent.
Website analytics and measurement
We use Google Analytics 4 through Google Tag Manager to understand website usage and improve the website. Analytics cookies and related storage are activated only after the applicable consent is provided through our cookie consent mechanism.
Legal basis: consent.
THIRD-PARTY SERVICE PROVIDERS
We use selected third-party service providers to operate the website and provide our services.
Framer
Our website is hosted and operated using Framer. Technical information may be processed as necessary to provide and secure the website.
Google Analytics and Google Tag Manager
We use Google Analytics 4 and Google Tag Manager for website measurement and analytics. Analytics processing is subject to the consent settings provided through our cookie banner.
Brevo
We use Brevo to manage email subscriptions and deliver the free Risk Management Guide and related communications. Where applicable, Brevo processes personal data on our behalf as a service provider.
Lemon Squeezy
Purchases of Primal Risk Manager products are processed through Lemon Squeezy. Lemon Squeezy acts as the merchant of record for transactions and processes customer and transaction data in connection with purchases, payment processing, tax handling, order management and product delivery.
Each provider may process personal data in accordance with its own privacy documentation and applicable data protection requirements.
COOKIES AND ANALYTICS
Our website uses necessary technologies required for website functionality.
We also use analytics technologies, including Google Analytics 4, to understand website traffic and usage. Analytics storage is not enabled before the applicable consent is provided.
You can manage your cookie and analytics preferences through the cookie consent interface available on our website.
DATA RETENTION
We retain personal data only for as long as necessary for the purposes for which it was collected, to provide our services, to maintain business and transaction records, or to comply with applicable legal obligations.
Where processing is based on consent, data will be processed in accordance with that consent until it is withdrawn, subject to any legal obligations requiring continued retention.
DATA TRANSFERS
Some service providers used by Primal Risk Manager may process personal data outside the European Economic Area.
Where personal data is transferred to a third country, appropriate safeguards required by applicable data protection law will be used where applicable.
For further information about the safeguards used by individual providers, please refer to their respective privacy documentation.
YOUR RIGHTS
Subject to applicable law, you may have the right to:
• Request access to your personal data
• Request correction of inaccurate or incomplete personal data
• Request deletion of your personal data
• Request restriction of processing
• Object to certain processing
• Request data portability where applicable
• Withdraw consent where processing is based on consent
To exercise your rights, contact:
We may need to verify your identity before processing certain requests.
RIGHT TO LODGE A COMPLAINT
If you believe that your personal data has been processed unlawfully, you have the right to lodge a complaint with the competent data protection supervisory authority.
In Hungary, the competent authority is:
National Authority for Data Protection and Freedom of Information (NAIH)
1055 Budapest, Falk Miksa utca 9–11.
Hungary
Website: naih.hu
DATA SECURITY
We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure or destruction.
However, no internet transmission or electronic storage system can be guaranteed to be completely secure.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes to our services, technology or legal requirements.
The latest version will always be published on this page.
Last updated: September 22, 2026