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DATA PROTECTION


Privacy policy of Privilege Properties Ltd.


The data controller, the purpose of the regulations


Name of the data controller: Privilege Properties Ltd. (hereinafter: “ciprusiingatlanok.hu”)


Registered office: Csalogány utca 23-33, 1027 Budapest.


Email: info@privilegeproperties.hu


Phone: +3670 298 8870 (working days 10.00 - 17.00



PRIVACY STATEMENT


Privilege Properties Ltd, as the operator of www.ciprusiingatlanok.hu, is committed to the protection of the personal data of its clients and partners and considers it extremely important to respect the right of its clients’ informational self-determination. Privilege Properties Ltd. treats personal data confidentially and takes all security, technical and organizational measures that guarantee the security of the data. Privilege Properties Ltd. describes its data management practices below:


Basic data:


 


Company name: Privilege Properties Kft.


 


Headquarters: Csalogány utca 23-33, 1027 Budapest.


 


Company registration number: 01 09 327463


 


Tax number: 26384832-2-41


Hereinafter the data controller acknowledges the content of this legal notice as binding on him / her. The data protection guidelines arising in connection with the data management of Privilege Properties Ltd. are continuously available at https://www.ciprusiingatlanok.hu/en/data-protecion 


Privilege Properties Ltd. reserves the right to change this prospectus at any time, and will notify its audience of any changes in a timely manner.


1. SCOPE OF PERSONAL DATA, PURPOSE, TITLE AND DURATION OF DATA PROCESSING


 


The data management of the activities of Privilege Properties Kft. Is based on voluntary consent.


We would like to draw the attention of informants to Privilege Properties Kft that if they do not provide their own personal data, the informant is obliged to obtain the consent of the data subject.


The data management principles of Privilege Properties Kft. Are in accordance with the applicable data protection legislation, in particular the following:


 


 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46 ( General Data Protection Regulation, GDPR);


2011 CXII. Act - on the right to information self-determination and freedom of information (Infotv.)


Act V of 2013 - on the Civil Code (Civil Code)


1997 CLV. Act - on Consumer Protection (Fgytv.)


Act C of 2000 - on Accounting (Act on Accounting)


CVIII of 2001 Act on Certain Issues of Electronic Commerce Services and Information Society Services (Eker Act)


Act C of 2003 - on electronic communications (Eht.)


XLVIII of 2008 Act on Certain Restrictions on Economic Advertising (Grt.)


2005 CXXXIII. Act on the Rules of Personal and Property Protection and Private Investigation (SZVMt.)



1.1 Contact Information


 


The purpose of data management: interest in the project and real estate on the ciprusiingatlanok.hu website, analysis of customer habits, more targeted service.


Legal basis for data processing: data processing is necessary for the performance of the contract [Article 6 (1) GDPR. (b)], the Court of Auditors. tv.169. § (2).


Type of processed personal data: name, email address, interest in the project, real estate.


Duration of data management:  8 years in accordance with Section 169 (2) of the Accouting Act.


Legal basis for the data transfer: data handling is necessary for the performance of the contract [Article 6 (1) GDPR. (b)].


Carrying out the system administratiors’ and web development tasks of ciprusiingatlanok.hu.


Across Media Ltd.; Budapest, Városligeti fasor 47, 1071


2. HANDLING COOKIES:


Based on section 20 (1) of the Act CXII of 2011 on the right to informational self-determination and freedom of information the following shall be determined within the scope of cookie data management of the website:


a) the fact of data collection,


b) the range of stakeholders,


c) the purpose of the data collection,


d) the duration of the data processing,


e) the identity of the potential data controllers entitled to access the data,


(f) a description of the data subjects' rights in relation to data processing.


 


The fact of data management, the scope of the managed data: unique identification number, dates, times


Stakeholders: All stakeholders who visit the website.


The purpose of data management : to identify users and track visitors.


Duration of data management, deadline for deleting data: The duration of data management in the case of session cookies lasts until the end of the visit to the websites.


Identity of potential data controllers who are entitled to access the data: Personal data may be processed by the data controller's staff, respecting the above principles.


Description of the data subjects' rights related to data management: The data subject has the possibility to delete cookies in the Tools / Settings menu of browsers, usually under the settings of the Privacy menu item.


Legal basis for data processing: The consent of the data subject is not required if the sole purpose of the use of cookies is the transmission of communication via an electronic communication network or the provision of an informational society service specifically requested by the subscriber or user.


3. METHOD OF STORAGE OF PERSONAL DATA, DATA MANAGEMENT


 

The data processors of Privilege Properties Ltd. implement appropriate technical and organizational measures, taking into account the state of the art and the costs of implementation, as well as the nature, scope, circumstances and purposes of data processing taking the varying likelihood and severity of the risk to the rights and freedoms of natural persons into consideration and guarantee a level of data security commensurate with the level of risk.

 



Privilege Properties Ltd. selects and operates the IT tools used for the management of personal data in such a way that the managed data:


- is accessible to those entitled to it (availability);


- its authenticity and authentication are ensured (authenticity of data management);


- its invariability can be verified (data integrity);


- is protected against unauthorized access (data confidentiality).


Privilege Properties Ltd. protects the data with appropriate measures, in particular against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as accidental destruction, damage, and becoming inaccessible due to changes in the applied technology.


 

In order to protect the electronically managed data files in its various registers, Privilege Properties Ltd. ensures the appropriate technical solution that the stored data, unless permitted by law, cannot be directly linked and assigned to the data subject.


In view of the current state of the art, Privilege Properties Ltd. ensures the protection of the security of data management with technical, organizational and institutional measures that provide a level of protection appropriate to the risks arising in connection with data management.


During data management Privilege Properties Ltd. retains


- confidentiality: protects information so that only those who are entitled to it can access it;


- integrity: protects the accuracy and completeness of the information and the method of processing;


- availability: ensures that when an authorized user needs it, he can actually access the information he wants and that the tools are available.


The IT system and network of Privilege Properties Ltd. and its data management partners are protected against computer-assisted fraud, espionage, sabotage, vandalism, fire and flood, as well as computer viruses, computer intrusions and denial-of-service attacks. The operator ensures security with server-level and application-level protection procedures. We inform users that electronic messages transmitted over the Internet, regardless of protocol (e-mail, web, ftp, etc.), are vulnerable to network threats that lead to unfair activity, contract disputes, or the disclosure or modification of information. To protect against such threats, the controller shall take all precautionary measures required of him. He monitors the systems to record any security incidents and provide evidence in case of any security incidents. System monitoring also makes it possible to check the effectiveness of the precautions taken.


 As a data controller, Privilege Properties Ltd. registers possible data protection incidents, indicating the facts related to the data protection incident, its effects and the measures taken to correct it. Privilege Properties Ltd. shall notify the National Data Protection and Freedom of Information Authority about any data protection incident without delay and, if possible, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is not likely to endanger the rights and freedom of natural persons.


3. OTHER DATA PROCESSES


 

Information on data processing not listed in this prospectus will be provided at the time of data collection. We inform our clients that the court, the prosecutor, the investigating authority, the infringement authority, the administrative authority, the National Data Protection and Freedom of Information Authority, or other bodies authorized by law may contact the data controller to provide information, disclose data, transfer documents or make documents available. 


Privilege Properties Ltd. provides personal data to the authorities - if the authority has indicated the exact purpose and scope of the data - only to the extent that is absolutely necessary to achieve the purpose of the request.


4. LEGAL REMEDIES



The data subject may request information on the processing of his/her personal data, as well as request the correction, deletion and restriction of personal data - except for mandatory data processing -and exercise his/her right of access to personal data and protest in the manner indicated at the time of data collection or via customer service.


 


Privilege Properties Ltd.,


Email: info@privilegeproperties.hu


By post: Privilege Properties Kft.,


1027 Budapest, Csalogány utca 23-33



4.1 Right to information:


 

At the request of the data subject, Privilege Properties Ltd. shall take appropriate measures in order to provide the data subject with all the information referred to in Articles 13. and 14. of the GDPR and all the information based on the Articles 15 to 22 and 34. shall be provided in a concise, transparent, comprehensible and easily accessible form, in a clear and comprehensible manner.


4.2 The data subject’s right of access:


 

The data subject has the right to receive feedback from the data controller as to whether the processing of his or her personal data is in progress and, if such data processing is in progress, he or she has the right to access the personal data and the following information: purposes of data processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be communicated, including in particular recipients in third countries or international organizations; the intended period for which the personal data will be stored; the right to rectify, erase or restrict data processing and to protest; the right to lodge a complaint with the supervisory authority; information on data sources; the fact of automated decision-making, including profiling, and comprehensible information on the logic used and the significance of such data management and the expected consequences for the data subject. In the event of a transfer of personal data to a third country or to an international organization, the data subject shall be entitled to be informed of the appropriate guarantees for the transfer. Privilege Properties Ltd. provides the data subject with a copy of the personal data that is the subject of data management. For additional copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs.



At the request of the data subject, the information is provided by Privilege Properties Ltd. in electronic form in writing.


Upon request, the data subject may be provided information orally upon verification and identification of his identity.


4.3 Right of correction:


 

Privilege Properties Ltd. corrects the personal data if it does not correspond to reality and the personal data corresponding to reality is available to you.


 

4.4 Right of cancellation:


 

If the data subject has any of the following reasons, Privilege Properties Ltd. is entitled to delete the personal data concerning him/her without undue delay at his/her request:


 a, personal data are no longer required for the purpose for which they were collected or otherwise processed;


 b, the data subject withdraws the consent on which the processing is based and there is no other legal basis for the processing;


 c, the data subject objects to the processing and there is no overriding legitimate reason for the processing;


 d, personal data have been processed unlawfully;


 e, personal data must be deleted in order to comply with a legal obligation under Union or Member State law applicable to the controller;


 f, personal data were collected in connection with the provision of information society services.


 

Deletion of data may not be initiated if the processing is necessary: for the purpose of exercising the right to freedom of expression and information; for the purpose of fulfilling an obligation under Union or Member State law applicable to the controller to process personal data or performing a task carried out in the public interest or in the exercise of official authority vested in the controller; in the field of public health, or for archival, scientific and historical research or statistical purposes, in the public interest; or to submit, assert or defend legal claims.


4.5 Right to restrict processing:


 


At the request of the data subject, Privilege Properties Ltd restricts the data processing if one of the following conditions is met: the data subject disputes the accuracy of the personal data - in this case the restriction applies to the period of time that allows the accuracy of the personal data to be checked;


 


- the processing is unlawful and the data subject opposes the deletion of the data and instead requests that their use be restricted;


 


- the controller no longer needs personal data for the purpose of data processing, but the data subject requests them in order to make, enforce or protect legal claims; or


 


- the data subject has objected to the processing; in that case, the restriction shall apply for as long as it is established whether the legitimate reasons of the controller take precedence over the legitimate reasons of the data subject.


 


If the processing is restricted, personal data may be processed, with the exception of storage, only with the consent of the data subject, or for the purpose of submitting, enforcing, or protecting legal claims, or protecting the rights of another natural or legal person or in the important public interest of the Union or a Member State.


 

Privilege Properties Ltd. informs the data subject in advance about the lifting of the data management restriction.


 


4.6 Right to data transmission:


 


The data subject shall have the right to receive the personal data concerning him or her made available to the controller in a structured, widely used, machine-readable format and to transmit this data to another controller.


 


4.7 Right to object:


 

The data subject shall have the right to object at any time, for reasons related to his situation, to the processing of his personal data in the public interest or in the exercise of a public authority conferred on the controller, or to the processing necessary for the legitimate interests of the controller or of a third party, including profiling based on those provisions.


 


In the event of an objection, the controller may not further process the personal data, unless justified by compelling legitimate reasons which take precedence over the interests, rights and freedoms of the data subject or which relate to the submission, enforcement or protection of legal claims.


 


Where personal data are processed for the purpose of direct business acquisition, the data subject shall have the right to object at any time to the processing of personal data concerning him for that purpose, including profiling, as far as it relates to direct business acquisition. In the event of an objection to the processing of personal data for the purpose of direct business acquisition, the data will not be processed by Privilege Properties Ltd. for this purpose.


4.8 Automated individual decision-making and profiling:


 


The data subject shall have the right not to be covered by a decision based solely on automated data processing, including profiling, which would have legal effects on him or her or would be similarly significant. The above right shall not apply if the processing is necessary for the conclusion or performance of a contract between the data subject and the controller; it is made possible by Union or Member State law applicable to the controller, which also lays down appropriate measures to protect the rights and freedoms and legitimate interests of the data subject; or is based onnthe explicit consent of the data subject.


 


4.9 Right of withdrawal:


 


The data subject has the right to withdraw his or her consent at any time. Withdrawal of consent shall not affect the lawfulness of the data processing prior to withdrawal.


 


4.10 Rules of procedure:


 


The controller shall, without undue delay, but in any case within one month of the receipt of the request, inform the data subject in accordance with Articles 15 to 22 of the GDPR on the action taken on a request pursuant to Article. If necessary, taking into account the complexity of the requests and the number of requests, this time limit may be extended by a further two months.


 


The controller shall inform the data subject of the extension of the time limit, indicating the reasons for the delay, within one month of receiving the request. If the data subject has submitted the request electronically, the information shall be provided electronically, unless the data subject requests otherwise.


 


If the controller does not take action on the data subject's request, it shall inform the data subject without delay, but no later than one month after receipt of the request, of the reasons for the non-action and of the data subject's right to appeal to a supervisory authority.


 


Privilege Properties Ltd. provides the requested information and public information free of charge. If the data subject's request is clearly unfounded or excessive, in particular because of its repetitive nature, the controller may charge a reasonable fee, based on the costs of providing the requested information, or refuse to act on the request, taking into account the administrative.


 


The controller shall inform all recipients to whom or with whom the personal data have been communicated of any rectification, erasure or restriction on the processing of personal data, unless this proves impossible or requires a disproportionate effort. Upon request, the controller shall inform the data subject of these recipients.


 


The data controller shall make a copy of the personal data which are the subject of the data processing available to the data subject. For additional copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. If the data subject has submitted the request electronically, the information shall be provided in electronic format, unless the data subject requests otherwise.


4.11 Compensation and restitution:


 


Any person who has suffered pecuniary or non-pecuniary damage as a result of a violation of the Data Protection Regulation is entitled to compensation from the controller or processor for the damage suffered. The data processor shall be liable for damages caused by the data processing only if it has not complied with the obligations specified in the law, which are specifically imposed on the data processors, or if it has disregarded or acted contrary to the data controller's lawful instructions. If several controllers or processors or both controllers and processors are involved in the same processing and are liable for damages caused by the processing, each controller or processor shall be jointly and severally liable for the total damage. The controller or processor shall be released from liability if he proves that he is not responsible in any way for the event giving rise to the damage.

 


4.12 Right to a fair trial:


 


In the event of a violation of his or her rights, the data subject may bring an action against the data controller (the data subject may choose to have jurisdiction over the defendant's domicile or residence). The court is acting out of turn in the case. A lawsuit filed in connection with the protection of personal data is duty-free.


 


4.13 Data protection authority procedure:


 


Complaints can be lodged with the National Data Protection and Freedom of Information Authority:


 


 Name: National Data Protection and Freedom of Information Authority


 


 Headquarters: 1125 Budapest, Szilágyi Erzsébet avenue 22 / C.


 


Express consent: Prior to the first use of the reservation and event reservation service provided by the User Privilege Properties Ltd. through www.ciprusiingatlanok.hu and the portal pointing to this, the User expressly acknowledges that he has read and accepted these Regulations and states that during the reservation expressly consents to the processing of his/her personal data.


 


 Budapest 04/24/2019


Privilege Properties Kft. reserves the right to change this prospectus at any time, and will notify its audience of any changes in a timely manner.

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