oif.gov.hu

Context

oif.gov.hu is the website of the National Directorate-General for Aliens Policing of Hungary (Országos Idegenrendészeti Főigazgatóság, OIF), the immigration control authority responsible for residence permits, registration of foreign nationals, and asylum and protection matters. Until 2019, the authority was known as the Office of Immigration and Nationality (Bevándorlási és Menekültügyi Hivatal), corresponding to the former domain bmbah.hu. The data controller is OIF. The site is served by an Apache/2.4.62 server (Debian). Capture: 54 requests, 8 domains, recorded in a clean browser.

Direct Recipients of Data (prior to consent)

Google (USA) — the visitor’s IP address via reCAPTCHA and Google Fonts. Bunny (Slovenia) — the visitor’s IP address via Bunny Fonts. unpkg — the visitor’s IP address via the loading of the Swiper library.

Declared versus Actual

Here the discrepancy is especially stark, because the authority makes a direct promise. OIF’s privacy notice states that the Directorate-General does not transfer data arising in connection with visiting the site to third parties — except for lawfully mandated targeted requests from authorities. The consent banner, in turn, promises that statistical and marketing cookies will load only after the visitor clicks “accept.” That is, on paper, the site is closed to third-party transfer and operates on a prior-consent model.

The capture reveals otherwise. At +781 ms, before any interaction with the banner, several external recipients connect at once. Some fonts have indeed been switched to privacy-oriented Bunny Fonts (fonts.bunny.net, the Nunito font) — a deliberate step in favor of privacy. But at the same time, Google reCAPTCHA loads (api.js from www.google.com, the runtime from www.gstatic.com at +1540 ms), along with Google Fonts (the Lora font from fonts.googleapis.com and fonts.gstatic.com at +989–1226 ms) and the Swiper 12.2.0 library from unpkg. All of these calls transmit the visitor’s IP address to third-party recipients: to Google (USA) via reCAPTCHA and Google Fonts, to Bunny (Slovenia) via Nunito, and to unpkg via Swiper. None of them is named in the policy, and the fact of the IP address transfer itself directly contradicts the statement that no data is transferred to third parties.

For this authority, the context makes the finding weightier. Its visitors are foreign nationals, refugees, and asylum seekers; for many of them, the default disclosure of an IP address to a US recipient carries quite different risks than it would for an ordinary visit to a government site. At the same time, there is no analytics (Google Analytics, Matomo) on the site at all, and no cookies are set during the session (Set-Cookie is zero) — meaning the issue lies specifically in the undisclosed transfer of the IP address to third-party recipients, not in tracking cookies.

Timing Relative to Consent

All external calls occur at +781–1540 ms, before any action by the visitor. The site has a consent banner that declares a consent model, but it does not hold back the loading of fonts, reCAPTCHA, or the CDN library — these calls occur outside the consent mechanism. No consent was given during the session (Set-Cookie is zero).

What Cannot Be Asserted from This Capture

The calls to bmbah.hu at the start of the capture are redirects from the authority’s former domain to the current oif.gov.hu, not a third-party tracker; the capture simply began at the old address. Bunny Fonts (operated by BunnyWay, Slovenia) is positioned as a privacy-oriented alternative to Google Fonts that does not log IP addresses for tracking purposes; of all the external recipients, it is therefore the least concerning — but formally it remains a third-party contact not named in the policy. Google may use edge nodes within the EU; for reCAPTCHA and Google Fonts, the conclusion drawn therefore concerns the recipient’s corporate affiliation (Google, USA), not the physical location of the node. unpkg is served through Cloudflare infrastructure — the conclusion concerns the recipient operator, not a specific node. reCAPTCHA is present in the form of api.js; the form to which it is attached is not necessarily visible in the home-page capture — the library is preloaded. Server-side processing is not visible in a browser-based capture.

Conclusion

The website of Hungary’s immigration authority has taken a step toward privacy — some fonts have been switched to Bunny Fonts, there is no analytics, and the banner declares a prior-consent model. Nevertheless, prior to any consent, the site transmits the visitor’s IP address to several third-party recipients: to Google, via reCAPTCHA and the remaining Google Fonts, to Bunny (Slovenia), and to unpkg. None of them is named in the policy, and the authority’s own privacy notice states directly that visit data is not transferred to third parties — which contradicts the site’s actual behavior. For an authority working with foreign nationals, refugees, and asylum seekers, the transfer of the IP address to undisclosed third-party recipients by default, on every visit, and outside any consent mechanism, indicates non-compliance with the requirements concerning disclosure of recipients and cross-border transfer, compounded by the heightened sensitivity of the audience. The remedy is largely within the authority’s own control: complete the work already begun — switch the remaining Google Fonts to locally hosted fonts or to the same Bunny service, host Swiper locally, and load reCAPTCHA only on pages containing forms and only after consent; this would leave practically no external calls prior to the visitor’s choice.