Privacy Policy

Last updated: October 30, 2026

1. INTRODUCTION

CloudTrust Kft. is committed to protecting the privacy, confidentiality and security of information processed through Renecto™.

This Privacy Policy explains how personal data and operational information are processed when users access or use the Renecto service.

Renecto is a secure remote network connectivity solution designed to establish encrypted Layer 2 network connections between remote endpoints. Its architecture combines TAP-based Ethernet networking, End-to-End encryption and secure SSL/TLS transport.

Privacy and data protection are fundamental principles of the Renecto architecture. The service is designed to minimise the information visible to the central infrastructure and to prevent access to the content of End-to-End encrypted network traffic.

This Privacy Policy applies to individuals and organisations using Renecto, including administrators, authorised users and connected endpoints.

2. DATA CONTROLLER AND SERVICE PROVIDER

The service is operated and provided by:

CloudTrust
Hungary

Website: https://cloudtrust.solutions
Renecto: https://renecto.com
Privacy contact: privacy@cloudtrust.solutions
Court of Registration: Metropolitan Court of Budapest, Company Court
Company Registration Number: 01-09-197036
EU VAT Number: HU25053768

Depending on the contractual relationship and deployment model, CloudTrust Kft. may act as a data controller or as a data processor on behalf of an organisation.

Where CloudTrust processes personal data on behalf of a customer, the respective organisation determines the purposes and means of processing, subject to the applicable agreement and data protection legislation.

3. PRIVACY BY DESIGN

3.1. Data Minimisation

Renecto is designed to minimise the information processed by the central infrastructure. The service processes operational information necessary to establish, maintain, secure and manage network connections.

3.2. End-to-End Data Confidentiality

Network traffic is encrypted at the source endpoint and is intended to be decrypted only by the authorised destination endpoint.

The central infrastructure and intermediary network components are not intended to access the decrypted content of End-to-End encrypted network traffic.

3.3. No Traffic Content Logging

Renecto does not log the content of network traffic as part of its standard operation.

The service is designed so that the central infrastructure cannot inspect or archive the decrypted content of properly protected End-to-End encrypted network packets.

3.4. Limited Operational Accounting

The infrastructure may record the total volume of data transmitted through the private network. This information is used for operational purposes, including bandwidth management, service administration and data usage quotas.

Such traffic accounting information does not represent the content of the transmitted network packets.

3.5. No Behavioural Profiling

Renecto is not designed to monitor users' internal network activity, create behavioural profiles or analyse the content of communications.

The service does not intentionally map internal network communication patterns or monitor device-level activity for profiling purposes.

3.6. Security by Design

Security measures are integrated into the architecture and operation of Renecto. These include End-to-End encryption, SSL/TLS transport security and authentication mechanisms designed to protect access to the network.

4. CATEGORIES OF DATA PROCESSED

Depending on the deployment, configuration and functionality used, Renecto may process the following categories of information.

4.1. Account and Identity Information

This may include usernames, email addresses, account identifiers, organisation details and information required to administer access to the service.

4.2. Authentication and Access Control Information

This may include authentication identifiers, public key information, authentication method details, access tokens, security settings and information associated with FIDO2, WebAuthn or TOTP authentication.

Where external identity providers are used, authentication-related information may also be processed by those providers.

4.3. Network Connection Information

The service may process technical information required to establish and maintain network connections, including endpoint identifiers, connection status, network addresses and connection-related technical parameters.

4.4. Traffic Accounting Information

The infrastructure may record aggregate traffic volume information associated with a private network or service account.

This information may be used to manage bandwidth limits, data usage quotas and other operational parameters.

4.5. Technical and Diagnostic Information

Technical information may include service status, timestamps, software versions, error information and diagnostic data necessary to maintain and troubleshoot the service.

5. PURPOSES OF DATA PROCESSING

Personal data and operational information may be processed for the following purposes:

5.1. Creating and managing user accounts.

5.2. Authenticating users and authorised endpoints.

5.3. Establishing and maintaining encrypted network connections.

5.4. Managing access permissions and network resources.

5.5. Measuring aggregate data transmission volumes.

5.6. Applying bandwidth restrictions and data usage quotas.

5.7. Maintaining service availability, reliability and security.

5.8. Diagnosing technical problems and resolving service incidents.

5.9. Preventing unauthorised access and misuse.

5.10. Complying with applicable legal and contractual obligations.

6. NETWORK TRAFFIC AND END-TO-END ENCRYPTION

Renecto uses a virtual TAP network adapter to provide Layer 2 connectivity between remote endpoints.

The service encapsulates Ethernet frames and protects network traffic through End-to-End encryption.

The encryption is applied at the source endpoint, and the corresponding authorised destination endpoint is responsible for decrypting the protected traffic.

The central infrastructure acts as an intermediary for the transmission of encrypted network traffic and is not intended to have access to its decrypted content.

The SSL/TLS transport channel provides an additional layer of protection for communication with the infrastructure.

The use of End-to-End encryption does not mean that no technical or connection-related information is processed. Information necessary to establish and maintain network connections may still be visible to the relevant infrastructure components.

7. TRAFFIC ACCOUNTING AND OPERATIONAL METRICS

Renecto may measure and record the total volume of data transmitted through a private network.

Such information is used exclusively for legitimate operational purposes, including:

7.1. Bandwidth management.

7.2. Data usage quotas.

7.3. Service capacity planning.

7.4. Operational administration.

7.5. Service performance management.

Traffic accounting is limited to aggregate transmission volume information and is not intended to include the content of network packets.

The service is not designed to use traffic accounting information to reconstruct the content of communications or create behavioural profiles.

8. AUTHENTICATION AND IDENTITY PROTECTION

Renecto supports modern authentication and access control mechanisms designed to protect network access.

Depending on the service configuration, these may include:

8.1. FIDO2 and WebAuthn authentication.

8.2. Hardware security keys, including compatible devices such as YubiKey.

8.3. Platform-based authentication mechanisms, including Windows Hello.

8.4. Biometric authentication supported by the user's device.

8.5. Time-Based One-Time Password authentication using compatible authenticator applications.

8.6. External identity providers and enterprise Single Sign-On integrations.

Authentication information is processed to verify identities, authorise access and protect the service against unauthorised connections.

Where an external identity provider is used, that provider may independently process personal data in accordance with its own privacy policy.

9. ENCRYPTION AND INFORMATION SECURITY

Renecto applies multiple security mechanisms to protect network communication and access to the service.

These may include:

9.1. End-to-End encryption of network traffic between authorised endpoints.

9.2. SSL/TLS encryption for transport connections to the infrastructure.

9.3. Cryptographic authentication of authorised endpoints.

9.4. Secure authentication and access control mechanisms.

9.5. Protection of authentication credentials and access tokens.

9.6. Infrastructure security and operational monitoring.

9.7. Security updates and vulnerability management.

The effectiveness of these measures depends on correct configuration, secure endpoint operation and the protection of cryptographic credentials.

Users and organisations remain responsible for maintaining the security of their own devices, operating systems and local network environments.

10. LEGAL BASIS FOR DATA PROCESSING

Personal data is processed on one or more of the following legal bases under Article 6 of the General Data Protection Regulation (GDPR), depending on the specific processing activity.

10.1. Performance of a Contract

Processing is necessary to provide Renecto, manage accounts, establish network connectivity and fulfil contractual obligations.

10.2. Compliance with a Legal Obligation

Processing is necessary to comply with applicable legal or regulatory requirements.

10.3. Legitimate Interests

Processing may be necessary for legitimate interests, including service security, infrastructure protection, operational management, technical troubleshooting and prevention of unauthorised access, provided that such interests are not overridden by the rights and freedoms of the data subject.

10.4. Consent

Where required by applicable law, processing may be based on the user's freely given, specific, informed and unambiguous consent.

Consent may be withdrawn at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

11. DATA RETENTION

Personal data and operational information are retained only for as long as necessary to fulfil the purposes for which they were collected or to comply with applicable legal, contractual and regulatory requirements.

Retention periods may depend on the type of information, service configuration, operational requirements and contractual arrangements.

Traffic accounting information may be retained for the period necessary to administer bandwidth limits, data usage quotas and related service functions.

Authentication and security-related information may be retained for as long as necessary to protect accounts, manage access and investigate security incidents.

When information is no longer required, it is deleted, anonymised or otherwise handled in accordance with applicable data protection requirements.

12. THIRD-PARTY SERVICES AND DATA PROCESSORS

Renecto may rely on third-party infrastructure and service providers to deliver specific functionalities.

These may include:

12.1. Hosting and infrastructure providers.

12.2. Network connectivity providers.

12.3. Identity and authentication providers.

12.4. Security and operational service providers.

12.5. Other providers necessary to operate the service.

Where third parties process personal data on behalf of CloudTrust Kft., appropriate contractual and organisational safeguards are applied.

External identity providers and other integrated services may independently process personal data under their own terms and privacy policies.

13. INTERNATIONAL DATA TRANSFERS

Personal data may be processed or accessed outside the European Economic Area where this is necessary for the provision of Renecto or the involvement of service providers.

Where personal data is transferred outside the European Economic Area, CloudTrust Kft. applies the safeguards required by applicable data protection legislation.

These safeguards may include European Commission adequacy decisions, Standard Contractual Clauses or other legally recognised transfer mechanisms.

14. DATA PROTECTION RIGHTS

Under the GDPR and applicable data protection legislation, individuals may have the following rights.

14.1. Right of Access

The right to obtain confirmation as to whether personal data concerning them is being processed and to access that data.

14.2. Right to Rectification

The right to request correction of inaccurate or incomplete personal data.

14.3. Right to Erasure

The right to request deletion of personal data where the applicable legal conditions are met.

14.4. Right to Restriction of Processing

The right to request restriction of processing in circumstances defined by applicable law.

14.5. Right to Data Portability

The right to receive certain personal data in a structured, commonly used and machine-readable format and, where legally applicable, to transmit it to another controller.

14.6. Right to Object

The right to object to processing based on legitimate interests or other applicable legal grounds where the conditions established by law are met.

14.7. Right to Withdraw Consent

Where processing is based on consent, the right to withdraw that consent at any time.

14.8. Right to Lodge a Complaint

The right to lodge a complaint with the competent supervisory authority.

Requests concerning data protection rights may be submitted using the privacy contact details provided in this policy.

15. DATA BREACHES AND SECURITY INCIDENTS

CloudTrust Kft. maintains procedures for identifying, assessing and responding to personal data breaches and security incidents.

Where a personal data breach occurs, CloudTrust Kft. will take appropriate measures to investigate and mitigate its effects.

Where required by the GDPR, the competent supervisory authority will be notified within the applicable statutory time limit.

Where a personal data breach is likely to result in a high risk to the rights and freedoms of individuals, affected individuals will also be informed as required by applicable law.

16. CHILDREN'S PRIVACY

Renecto is not specifically designed to collect personal data from children.

Where the service is used in educational or other environments involving children, the organisation responsible for providing access must ensure that the use of the service and the associated personal data processing comply with applicable data protection and child protection legislation.

17. CHANGES TO THIS PRIVACY POLICY

CloudTrust Kft. may update this Privacy Policy from time to time to reflect changes in the service, technical architecture, data processing practices or applicable legislation.

The latest version will be made available through the Renecto website or the relevant application interface.

The date of the latest revision will be indicated at the beginning of the document.

18. CONTACT AND SUPERVISORY AUTHORITY

For questions, requests or concerns relating to this Privacy Policy or the processing of personal data, please contact:

CloudTrust
Hungary

Website: https://cloudtrust.solutions
Renecto: https://renecto.com
Privacy contact: privacy@cloudtrust.solutions
Court of Registration: Metropolitan Court of Budapest, Company Court
Company Registration Number: 01-09-197036
EU VAT Number: HU25053768

Hungarian Supervisory Authority:

National Authority for Data Protection and Freedom of Information (NAIH)
Address: 1055 Budapest, Falk Miksa utca 9-11, Hungary
Website: https://www.naih.hu
Email: ugyfelszolgalat@naih.hu

Individuals have the right to lodge a complaint with the competent supervisory authority if they believe that the processing of their personal data infringes applicable data protection legislation.

Privacy is not an add-on. It is part of the architecture.