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Technical audit · 29.05.2026

mtva.hu

Hungarian Public Media Fund
HU

Policy changed — see what exactly · 2026-08-14 →

The Hungarian Public Media Fund (MTVA) — 163 requests, 17 domains. An InMobi consent management platform (IAB TCF) is present, but advertising does not wait for it: Google Ad Manager, the Facebook SDK, and prebid wrappers load before and around the banner. Meanwhile, MTVA's official policy states directly that data is not transferred to third parties.

Request timeline

+0 ms · portal load
Markup and some resources — served from the first-party domain mtva.hu and the public broadcaster's player (player.mediaklikk.hu). The video.js and jQuery libraries are pulled from CDNs (cdnjs, code.jquery.com).
+498…+608 ms · advertising and Facebook prior to the banner
cdn.atmedia.hu and cdn.publisher1st.com — prebid header bidding; securepubads.g.doubleclick.net/tag/js/gpt.js — Google Ad Manager; connect.facebook.net/sdk.js — the Facebook SDK. All prior to the appearance of the consent banner.
+645 ms · the InMobi CMP appears after advertising
cmp.inmobi.com/choice — loading of the InMobi consent management platform, built on the IAB TCF standard. By this point, the Google advertising tag, the Facebook SDK, and prebid have already executed.
session state — no consent
Set-Cookie across the entire session is zero; no choice has been made by the user. Advertising and social modules are already loaded.
+2160…+2615 ms · GTM and Facebook widgets
www.googletagmanager.com/gtm.js, www.facebook.com/plugins/share_button.php, and static.xx.fbcdn.net — Google Tag Manager and Facebook social share buttons, with no consent having been collected.

Declared versus actual

✓ InMobi consent management platform (IAB TCF) — 'Accept All' / 'Reject' — declared
✓ MTVA's official policy — personal data is not transferred to third parties, except in legally required cases — declared
+ Google Ad Manager, the Facebook SDK, and prebid fire before the consent banner appears — not declared
+ The transfer of the IP address to advertising recipients (Google, Meta, atmedia, Publisher1st) directly contradicts the policy's statement that data is not transferred to third parties — not declared

Transfer timings

+498 ms cdn.atmedia.hu

Prebid from the Hungarian advertising network atmedia.

+604 ms securepubads.g.doubleclick.net

Google Ad Manager (GPT). Google, USA. Before the CMP.

+608 ms connect.facebook.net

Facebook SDK. Meta, USA.

+645 ms cmp.inmobi.com

InMobi CMP (IAB TCF). The consent banner.

Detected trackers

Indicators of GDPR non-compliance

Context

mtva.hu is the website of the Media Support and Asset Management Fund (Médiaszolgáltatás-támogató és Vagyonkezelő Alap, MTVA), the state body that funds and supports content production for Hungarian public broadcasting. The data controller is MTVA. Capture: 163 requests, 17 domains, recorded in a clean browser.

Google (USA) — Ad Manager (GPT), Tag Manager, the Google+ platform, Fonts. Meta/Facebook (USA) — SDK and share buttons. atmedia, Publisher1st — prebid advertising wrappers.

Declared versus Actual

Here the discrepancy is especially stark. MTVA’s official policy (in its legal and privacy notice section) states directly: personal data is not transferred to third parties, except in legally required cases — contractual obligations, judicial, prosecutorial, supervisory, and other lawful procedures. The policy says nothing about advertising monetization or advertising partners.

The capture reveals the opposite. The site runs a full-scale advertising machine, and does so before the consent management platform even appears. At +498–500 ms, prebid wrappers from the Hungarian advertising networks atmedia (cdn.atmedia.hu) and Publisher1st (cdn.publisher1st.com) connect. At +604 ms, the Google Ad Manager advertising tag starts (securepubads.g.doubleclick.net/tag/js/gpt.js), and at +608 ms, the Facebook SDK (connect.facebook.net). Only at +645 ms does the InMobi consent management platform itself load (cmp.inmobi.com/choice), built on the IAB TCF standard. That is, the Google advertising tag, the Facebook SDK, and prebid execute before the visitor even sees the consent banner.

Subsequently, at +2160 ms, Google Tag Manager loads, and at +2190–2615 ms, Facebook social share buttons (www.facebook.com/plugins/share_button.php, static.xx.fbcdn.net). Additionally, at +226 ms, the Google+ platform (apis.google.com) and Google Fonts connect. No cookies are set in the captured headers (Set-Cookie is zero), but the absence of cookies does not negate the transfer of the IP address to advertising and social recipients that has already taken place. Thus, the policy’s statement that data is not transferred to third parties directly contradicts the site’s actual advertising monetization.

Prebid fires at +498 ms, Google Ad Manager at +604 ms, the Facebook SDK at +608 ms, the InMobi banner at +645 ms, and GTM plus the share buttons at +2160–2615 ms. Advertising and social modules precede the consent banner. No consent was given during the session (Set-Cookie is zero).

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 script loading (GPT, the Facebook SDK, prebid, GTM), rather than from cookie headers. Behavior following a click on “accept” or “reject” in the InMobi banner is not observed in this session. Google and Meta may use edge nodes within the EU; the conclusion drawn therefore concerns the recipients’ corporate affiliation (US companies), not the physical location of the nodes. Server-side processing is not visible in a browser-based capture.

Conclusion

The website of Hungary’s public media fund is equipped with an InMobi consent management platform, but advertising and social modules do not wait for it: Google Ad Manager, the Facebook SDK, and prebid wrappers start before the banner, transmitting the visitor’s IP address to advertising recipients in the USA and to advertising networks. It is particularly significant that MTVA’s official policy states directly the opposite — that personal data is not transferred to third parties. The discrepancy between what is declared and what actually occurs here is fundamental: the policy denies any data transfer, while the site runs full-scale advertising monetization prior to consent. For a state body responsible for public broadcasting, this indicates non-compliance with the requirements concerning the legal basis for processing, disclosure of recipients, and cross-border transfer. Remedy: link advertising and social tags to the consent management platform and hold them back until actual consent is given, and bring the policy into line with the actual set of data recipients.

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/mtva-hu-2026-05-29.har
SHA-256: ab09b78b5a39b041a0187b904ef76ce007735fa0d1f7a47205ce91e62f4ab53d
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) — mtva.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 mtva.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, before and in parallel with the appearance of the InMobi consent management platform (cmp.inmobi.com at +645 ms), advertising and social services fire: prebid wrappers from atmedia and Publisher1st (at +498–500 ms), the Google Ad Manager advertising tag (securepubads.g.doubleclick.net/tag/js/gpt.js at +604 ms), and the Facebook SDK (connect.facebook.net at +608 ms). The InMobi consent management platform appears after them. No cookies are set in the captured headers (Set-Cookie is zero); no choice has been made by the user.

2) MTVA's official policy states directly that personal data is not transferred to third parties, except in legally required cases. The capture, however, shows full-scale advertising monetization: prior to consent, the visitor's IP address is transmitted to advertising recipients in the USA (Google — Ad Manager, Tag Manager; Meta/Facebook) and to advertising networks (atmedia, Publisher1st). This directly contradicts the policy's statement that data is not transferred to third parties.


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-mtva-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 — mtva.hu

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

2. Circumstances
I visited the website mtva.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, before and in parallel with the appearance of the InMobi consent management platform (cmp.inmobi.com at +645 ms), advertising and social services fire: prebid wrappers from atmedia and Publisher1st (at +498–500 ms), the Google Ad Manager advertising tag (securepubads.g.doubleclick.net/tag/js/gpt.js at +604 ms), and the Facebook SDK (connect.facebook.net at +608 ms). The InMobi consent management platform appears after them. No cookies are set in the captured headers (Set-Cookie is zero); no choice has been made by the user.

2) MTVA's official policy states directly that personal data is not transferred to third parties, except in legally required cases. The capture, however, shows full-scale advertising monetization: prior to consent, the visitor's IP address is transmitted to advertising recipients in the USA (Google — Ad Manager, Tag Manager; Meta/Facebook) and to advertising networks (atmedia, Publisher1st). This directly contradicts the policy's statement that data is not transferred to third parties.

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

3. GDPR provisions I ask you to examine
GDPR Art. 6 + ePrivacy (Hungarian implementation) — advertising and social trackers prior to consent; GDPR Art. 13(1)(e) + Chapter V — disclosure of recipients and cross-border transfer, contradiction with the policy

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]