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Technical audit · 29.05.2026

mta.hu

Hungarian Academy of Sciences
HU

The Hungarian Academy of Sciences (MTA) — 184 requests, 5 domains. There is no consent banner on the page: Google Analytics and self-hosted Piwik/Matomo fire immediately on load and register the visit before any choice is made, with Google Analytics transmitting data with no consent signal. Additionally, fonts from cloud.typography.com (USA) load prior to consent.

Request timeline

+0 ms · portal load
Markup, stylesheets, scripts, and images — served from the first-party domain mta.hu. Some content is served from the academy's own subdomain.
+399 ms · Google Tag Manager and fonts prior to consent
www.googletagmanager.com/gtag/js (identifier G-45NN4EM3BG) and cloud.typography.com — the Hoefler&Co font service (USA). Both fire on page load.
no consent banner present
There is no consent management platform or consent banner in the capture. Analytics fires unconditionally.
+637 ms · Google Analytics without consent
region1.google-analytics.com/g/collect — a GA4 hit request. There is no Consent Mode signal (gcs) in the request. Set-Cookie across the session is zero; no choice has been made by the user.
+2587…+3262 ms · Piwik registers the visit without consent
doktar.titkarsag.mta.hu/analytics/piwik/piwik.js, followed by piwik.php with rec=1 — self-hosted analytics on the academy's subdomain that actually registers the visit (visitor identifier, page URL).

Declared versus actual

✓ Under Hungarian law, analytics (statistical) cookies are activated only with the visitor's consent (GDPR Art. 6(1)(a)) — declared
✓ MTA's structures use Google Analytics and Piwik/Matomo for traffic statistics — declared
+ Google Analytics (GA4 G-45NN4EM3BG) and Piwik/Matomo fire and register the visit prior to consent — not declared
+ No consent banner is present in the capture; the Google Analytics request carries no Consent Mode signal (gcs) — not declared
+ cloud.typography.com (Hoefler&Co, USA) — third-party recipient of IP address, prior to consent — not declared

Transfer timings

+399 ms www.googletagmanager.com

Google Tag Manager (G-45NN4EM3BG). Google, USA.

+400 ms cloud.typography.com

Hoefler&Co / Monotype fonts. USA.

+637 ms region1.google-analytics.com

GA4 g/collect. No gcs signal present.

+3262 ms doktar.titkarsag.mta.hu

Piwik piwik.php rec=1 with a visitor identifier. Self-hosted.

Detected trackers

Indicators of GDPR non-compliance

Context

mta.hu is the website of the Hungarian Academy of Sciences (Magyar Tudományos Akadémia, MTA), the country’s top scientific institution. The data controller is MTA. Capture: 184 requests, 5 domains, recorded in a clean browser.

Google (USA) — the visitor’s IP address via Google Analytics and Google Tag Manager. Hoefler&Co / Monotype (USA) — IP address via the font service cloud.typography.com. Piwik/Matomo is hosted on the academy’s own subdomain and does not transmit data to an external recipient.

Declared versus Actual

Under Hungarian law and common practice among scientific and government sites, analytics (statistical) cookies are classified as non-essential and are activated only after the visitor’s consent. The academy’s own materials name Google Analytics and Piwik/Matomo as the statistics tools in use.

The capture shows that on the home page, both analytics systems fire prior to any consent and without a banner. At +399 ms, Google Tag Manager connects (identifier G-45NN4EM3BG), and at +637 ms Google Analytics 4 sends a visit-registration hit request (region1.google-analytics.com/g/collect); the request carries no Consent Mode signal (the gcs parameter), meaning consent is not collected and this is not signaled to Google. A second analytics system operates in parallel: self-hosted Piwik/Matomo on the academy’s subdomain (doktar.titkarsag.mta.hu) sends, at +3262 ms, a request to piwik.php carrying the parameter rec=1, denoting the actual registration of the visit, together with a unique visitor identifier and the page URL. That is, the visit is recorded twice — both in Google and in the academy’s own Piwik — before any choice is made by the user.

Additionally, at +400 ms, fonts load from the third-party service cloud.typography.com (Hoefler&Co / Monotype, USA), transmitting the visitor’s IP address to a third-party recipient. No consent management platform or consent banner is present on the page at all. No cookies are set in the captured headers (Set-Cookie is zero).

Google Tag Manager and the fonts load at +399–400 ms; Google Analytics visit registration at +637 ms; Piwik visit registration at +3262 ms. All of this occurs before any choice is made by the user. There is no consent banner on the page that could have preceded any of this. No consent was given during the session, and there is no Consent Mode signal in the Google Analytics request.

What Cannot Be Asserted from This Capture

The capture covers the home page in its pre-consent state. Set-Cookie is absent from the captured headers; the conclusion is drawn from the fact of GTM loading and from the visit-registration hit requests of Google Analytics and Piwik, rather than from cookie headers. Piwik/Matomo is hosted on the academy’s own subdomain, so its data is not transmitted to a third-party recipient; the issue here is the legal basis for recording the visit prior to consent. Google and Monotype may use edge nodes within the EU; the conclusion drawn therefore concerns the recipients’ corporate affiliation (US companies), not the location of the nodes. Server-side processing is not visible in a browser-based capture.

Conclusion

The website of the Hungarian Academy of Sciences launches two analytics systems at once — Google Analytics and self-hosted Piwik/Matomo — on page load, without any consent banner, and both actually register the visitor’s visit; Google Analytics, moreover, transmits data with no Consent Mode signal. Additionally, prior to consent, the visitor’s IP address is transmitted to Google and to a US-based font service. Under Hungarian law, analytics cookies require consent. Launching analytics and registering the visit by default, on every visit, and outside any consent mechanism, together with the transfer of the IP address to third-party recipients in the USA, indicates non-compliance with the requirements concerning the legal basis for processing and cross-border transfer. Remedy: implement a consent banner and hold back Google Analytics, Piwik, and the third-party fonts until actual consent is given, or switch Piwik to a fully anonymous statistics mode without identifiers and host the fonts locally.

Evidence

How to verify: download the file and compute its checksum — sha256sum file.har (Linux, macOS) or certutil -hashfile file.har SHA256 (Windows); it must match the one shown. The conclusions apply to the scope of this measurement — see the limitations of the method.

Original (audit)
HAR file: hu/mta-hu-2026-05-29.har
SHA-256: 2003ff07dce30e0ab82e0c16de693869490afe8eb0f7258c43ab0eea95cc98ff
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.
Want a response from the company about this audit? → Open the tool

Fill in once — it will be inserted into every letter below:

All fields are required to print the document — this is a formal requirement of the letter itself (the particulars of an official submission), not data collection: nothing is sent or saved anywhere, it all stays in your browser and disappears when you close the page. See the methodology for details.

Step 1. Data access request (GDPR Art. 15)

Send this letter directly to the company first — before contacting the regulator it has the right to respond (GDPR Art. 12(3) — 30 days).

Subject: Data access request (GDPR Art. 15) — mta.hu

To: [insert the company's address — DPO / support / legal department]
From: [Your name], [contact email]

I request access to my personal data processed in connection with the website mta.hu.

1. Categories of data and purposes of processing (Art. 15(1)(a)-(c))
Based on an independent technical analysis of the site, I request confirmation and detailed disclosure of the following categories of processing:

1) On page load, without any consent banner whatsoever, two analytics systems fire simultaneously. Google Tag Manager and Google Analytics 4 (identifier G-45NN4EM3BG) send a hit request to region1.google-analytics.com/g/collect (at +637 ms); the request carries no Consent Mode signal (gcs), meaning consent is not signaled. In parallel, self-hosted Piwik/Matomo on the academy's own subdomain (doktar.titkarsag.mta.hu) sends a request to piwik.php carrying rec=1 (an actual visit recording), a unique visitor identifier (_id), and the page URL. No consent management platform or consent banner is present in the capture. Under Hungarian law, analytics cookies are activated only with consent.

2) Prior to consent, the visitor's IP address is transmitted to Google (Analytics, Tag Manager) and to the font service cloud.typography.com (Hoefler&Co / Monotype), both US companies. Google Analytics transmits data with no consent signal.


2. Recipients, retention periods, and transfers outside the EEA (Art. 15(1)(c)-(d), 46)
I also request the full list of third-party recipients, the applicable retention period for each category, and the legal basis for any transfer of data outside the EEA. The full technical audit with evidence (saved network log, SHA-256 checksum) is published at: https://gdpru.eu/en/audits/hu-mta-hu/

3. Automated processing and profiling (Art. 15(1)(h))
Please state whether I am subject to automated decision-making or profiling, and if so, disclose the logic involved.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]
IMPORTANT: before filing a complaint with the regulator, first contact the company directly and give it 30 days to respond. Without this step the regulator may reject the complaint. Details and a template letter to the company are in the Methodology.
Ready-to-send complaint letter

Where to file: Hungarian National Authority for Data Protection (NAIH) — file a complaint online →

The regulator reviews complaints in its national language. There is an officially translated template from the European Data Protection Board (EDPB) — you can use it instead of or alongside this letter: Official EDPB complaint form (PDF, your language)

Subject: Complaint regarding personal data processing — mta.hu

1. Subject of the complaint
I am filing a complaint regarding the processing of my personal data by the website mta.hu.

2. Circumstances
I visited the website mta.hu and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 29 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) On page load, without any consent banner whatsoever, two analytics systems fire simultaneously. Google Tag Manager and Google Analytics 4 (identifier G-45NN4EM3BG) send a hit request to region1.google-analytics.com/g/collect (at +637 ms); the request carries no Consent Mode signal (gcs), meaning consent is not signaled. In parallel, self-hosted Piwik/Matomo on the academy's own subdomain (doktar.titkarsag.mta.hu) sends a request to piwik.php carrying rec=1 (an actual visit recording), a unique visitor identifier (_id), and the page URL. No consent management platform or consent banner is present in the capture. Under Hungarian law, analytics cookies are activated only with consent.

2) Prior to consent, the visitor's IP address is transmitted to Google (Analytics, Tag Manager) and to the font service cloud.typography.com (Hoefler&Co / Monotype), both US companies. Google Analytics transmits data with no consent signal.

Full technical documentation is published at: https://gdpru.eu/en/audits/hu-mta-hu/

3. GDPR provisions I ask you to examine
GDPR Art. 6 + ePrivacy (Hungarian implementation) — analytics prior to consent, with no banner; GDPR Art. 13(1)(e) + Chapter V — third-party recipient prior to consent

4. Request
I request that you examine the circumstances described and, if non-compliance is confirmed, apply the measures provided for in Article 58(2) GDPR.

5. Attachments
The full evidence base — the HAR file, its SHA-256 checksum and the quotation from the site's privacy policy documenting the stated contradiction — is published and verifiable at the link in point 2 above.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]