1. Designation of Data Controller(s):
Otthon Centrum Network, which includes the following:
- Otthon Centrum Franchising Ltd. (headquarters: 1023 Budapest, Lajos utca 28-32., company registration number: 01-
09-717482, represented by Katalin Kühne), a member of the Otthon Centrum group of companies
- Franchise Partner companies in a franchise relationship with Otthon Centrum Franchising Ltd.
- HC Center Ltd. (headquarters: 1023 Budapest, Lajos utca 28-32., MNB registration number: EN-I- 707/2010, company registration number: 01-09-716975, represented by László Bánfalvi), a member of the Otthon Centrum group of companies
- Otthon Centrum Solutions Ltd. (headquarters: 1023 Budapest, Lajos utca 28-32., company registration number: 01-09-728100, represented by Edit Vincze), a member of the Otthon Centrum group of companies.
- OC Finance Insurance Brokerage Ltd. (headquarters: 1023 Budapest, Lajos utca 28-32., company registration number: 01-09-730023), a member of the Otthon Centrum Group of companies.
The members of the Otthon Centrum Network are considered joint data controllers, which means that the purpose and means of the data processing defined in this data management notice are determined jointly. The data management practices of the Otthon Centrum Network are based on the European Union's General Data Protection Regulation (GDPR) 2016/679, and the 2011 Act CXII on the Right of Informational Self-Determination and on Freedom of Information.
2. Purpose, legal basis, scope of managed data, and those with access
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Purpose of Data Management |
Legal Basis for Data Management |
Scope of Managed Data |
Who has access to the data? |
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A. |
providing real estate brokerage services to the client under contract |
Article 6(1)(b) of the GDPR - data processing necessary for the performance of a contract |
client's name, birth name, address, mother's name, place and date of birth, email address, phone number, property details, parameters |
The client's personal data can be accessed by Otthon Centrum Franchising Ltd. and - the Franchise Partner within the Otthon Centrum Network, or the real estate advisor in legal relation with the Franchise Partner who has the client's property in their portfolio, or who has a prospective buyer interested in viewing the property. |
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enforcing Otthon Centrum Network's lawful civil claims in case of transaction bypassing the real estate broker. |
Article 6(1)(f) of the GDPR - legitimate interests pursued by the data controller |
client's name, birth name, address, mother's name, place and date of birth, email address, phone number |
The client's personal data can be accessed by Otthon Centrum Franchising Ltd. and - the Franchise Partner within the Otthon Centrum Network, or the real estate advisor in legal relation with the Franchise Partner who has the client's property in their portfolio. |
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client due diligence as required by the 2017 Act LIII. on the Prevention and Impediment of Money Laundering and Terrorism Financing (Pmt.) |
mandatory data management as required by the 2017 Act LIII. on the Prevention and Impediment of Money Laundering and Terrorism Financing (Pmt.) |
client's name, birth name, address, mother's name, place and date of birth, nationality, type and number of identification document, for foreign private individuals, the place of stay |
The client's personal data can be accessed by Otthon Centrum Franchising Ltd. and - the Franchise Partner within the Otthon Centrum Network who is/was in contractual relation with the client. |
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obligation to retain accounting documents |
obligation to retain accounting documents as prescribed by Section 169(2) of the Accounting Act of 2000 |
client's name, address, amount of invoice, other data of the invoice |
The client's personal data can be accessed by the Franchise Partner within the Otthon Centrum Network who issued the accounting document to the client. |
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B. |
Direct marketing information about the services of the Otthon Centrum Network and the companies in the Otthon Centrum group, particularly: - financial products/services mediated by HC Center Ltd. - valuation services provided by Otthon Centrum Solutions Ltd. or the opportunity to order energy certificates through it. - investment and/or insurance products mediated by OC Finance Insurance Brokerage Ltd. |
Article 6(1)(a) of the GDPR - voluntary consent of the data subject |
the client's name, phone number, email address, property details |
- Otthon Centrum Franchising Ltd. and - HC Center Ltd. and its subcontractors in contractual relation for providing financial services, and - Otthon Centrum Solutions Ltd. and its subcontractors in contractual relation for service provision, - OC Finance Insurance Brokerage Ltd. and its subcontractors in contractual relation for providing mediation services. |
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Transferring the client's data to the energy certification company (Eco Energy Group Hungary Ltd.) in the event of property sales, to enable contact with the client for service provision. |
Article 6(1)(a) of the GDPR - voluntary consent of the data subject |
- Otthon Centrum Franchising Ltd. and - Otthon Centrum Solutions Ltd. and - the energy certification company performing the service (Eco Energy Group Hungary Ltd., headquarters: 2900 Komárom, Igmándi út 6.) |
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Transferring the client's data to the company providing 3D virtual tour services (Panomedia Ltd.) to enable contact with the client for service provision. |
Article 6(1)(a) of the GDPR - voluntary consent of the data subject |
the client's name, phone number, property details |
- Otthon Centrum Franchising Ltd. and - the company providing the 3D virtual tour service (Panomedia Ltd., headquarters: 6726 Szeged, Pillich Kálmán street 15. I. floor 1.) |
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Customer satisfaction inquiries, sending questions to clarify customer needs by email and/or phone |
Article 6(1)(a) of the GDPR - voluntary consent of the data subject |
- name - email address - phone number - property parameters - responses to questions qualifying customer needs - responses to customer satisfaction questionnaires |
- Otthon Centrum Franchising Ltd., as well as the Franchise Partner and the real estate advisor in direct contact with the client |
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market research, market analyses, statistics creation |
Article 6(1)(a) of the GDPR - voluntary consent of the data subject |
property details, data related to property sales (e.g., advertising price, sale price, etc.) |
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3. Data Transfer
The Otthon Centrum Network may transfer client data to the Financial Intelligence Unit within the National Tax and Customs Administration in cases specified by the Pmt.
Otthon Centrum Solutions Ltd. will transfer the client's name, phone number, and property details to the energy certification provider Eco Energy Group Hungary Ltd. in the event of a property sale.
Otthon Centrum Franchising Ltd. will transfer the client's name, phone number, and property details to the 3D virtual tour provider Panomedia Ltd.
The Otthon Centrum Network may transfer the client's personal data in case of circumventing the Otthon Centrum Network for property sales to enforce civil legal claims to the attorney, law office, or debt collection company commissioned by it or the Franchise Partner.
The Otthon Centrum Network may transfer the client's personal data to the Buyer in the event of a property sale to prepare the real estate sales contract.
4. Duration of Data Management
The duration of data management based on the Pmt. is 8 years from the termination of the business relationship.
The duration of data management for data processed based on a contractual relationship with the client is 5 years from the termination of the business relationship.
In cases of data management based on voluntary consent, the duration of data management lasts until the withdrawal of consent but no longer than 2 years from the termination of the business relationship. After this period, the data controller will no longer use the client's data for the affected purposes.
5. Data Processors
Those natural or legal persons who process personal data related to data subjects on behalf of the Data Controller under a contractual relationship are considered data processors. The Otthon Centrum Network employs data processors during data management. Data processors do not make independent decisions; they are authorized to act only according to the contract with the Data Controllers and the instructions received. The data processors in the context of the services and data management referred to in this notice may include:
- Those assisting in the activities of the Otthon Centrum Network under a contractual relationship with Otthon Centrum Franchising Ltd., Otthon Centrum Solutions Ltd., the Franchise Partners, HC Center Ltd., or OC Finance Insurance Brokerage Ltd., such as real estate advisors, office managers, administrative staff, mortgage brokers, insurance brokers, appointed appraisers, and software providers.
6. Rights of the Data Subjects
Clients are entitled at any time to request information about the personal data processed by the Otthon Centrum Network, to request the correction of incorrect data, and to modify them in case of changes.
Clients may prohibit further use of their personal data for purposes where data processing is based on their voluntary consent by sending a letter to the address of Otthon Centrum Franchising Ltd. (1023 Budapest, Lajos utca 28-32) or an email to ugyfelszolgalat@oc.hu at any time; they are also entitled to object to data processing necessary for the pursuit of the legitimate interests of the Otthon Centrum Network.
Clients can unsubscribe from further newsletters and offers by clicking the unsubscribe link found at the bottom of the newsletters and offers sent by us. Please note that if our client wishes to prohibit further emails, newsletters, and other inquiries, they must unsubscribe using all the email addresses provided by them.
7. Client Obligations
The Franchise Partner of the Otthon Centrum Network that has a commission contract with the client is required by the Pmt. to demand the presentation of an identification document from the client for the purpose of verifying identity and to check the validity of the document as well as to make a copy of it.
The Franchise Partner of the Otthon Centrum Network that has a commission contract with the client is also required to ensure that the data related to the business relationship are up to date. Therefore, the client is obliged to inform the Franchise Partner within five working days of becoming aware of any changes to the data previously provided by showing the official document proving identity and the official document proving the address.
8. Remedies
The client may address any questions, comments, or complaints related to data management to the Otthon Centrum Network by sending an email to ugyfelszolgalat@oc.hu or a letter to the headquarters at 1023 Budapest, Lajos utca 28-32.
In case of a complaint regarding data management, the client may submit a petition to the National Authority for Data Protection and Freedom of Information or initiate legal proceedings at the court of jurisdiction based on their residence (place of stay).