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Data Management Notice for Clients Viewing Properties

1. Name of the 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 corporate group

- Franchise Partner businesses 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 corporate group

- 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 corporate group.

- OC Finance Insurance Brokerage Ltd. (headquarters: 1023 Budapest, Lajos utca 28-32., company registration number: 01-09-730023), a member of the Otthon Centrum Corporate Group.

The members of the Otthon Centrum Network qualify as joint data controllers based on the agreement between them, meaning that the purpose and tools of data management specified in this data management notice were determined jointly. The data management practice of the Otthon Centrum Network is based on the European Union's General Data Protection Regulation 2016/679, and the 2011 Act CXII on Informational Self-Determination and Freedom of Information.

2. The purpose of data management, legal basis, scope of managed data, those authorized to access the data

Legal Basis for Data Management

The client's personal data can be accessed by Otthon Centrum Franchising Ltd. and the Otthon Centrum Network's Franchise Partner, and the real estate advisor who has the viewed property in their portfolio or who presented the property to the client.

Purpose of Data Management

Scope of Managed Data

Who Can Access the Data?

A.

providing real estate brokerage services to the client

Article 6 of the GDPR

(paragraph 1 a.)

- the client's voluntary consent

the client's name, birth name, address, mother's name, place of birth, time of birth, phone number, email address, the registration number of the viewed/to be viewed property(ies), address, date of property viewing with the real estate advisor

The Client's personal data

- Otthon Centrum Franchising Ltd. and

- the Otthon Centrum Network's Franchise Partner, and the real estate advisor or other collaborator in a legal relationship with the Franchise Partner who has the client's desired property in their portfolio, or advertises such a property, or who has the specific property viewed by the client in their portfolio, or advertises it.

in the event of circumventing the real estate agent during a transaction, the enforcement of the Otthon Centrum Network's legitimate civil legal claim.

Article 6 of the GDPR

(paragraph 1 f.)

- enforcement of the data controller's legitimate interest

the client's name, birth name, address, mother's name, place of birth, time of birth, phone number,

email address,

the registration number of the viewed/to be viewed property(ies), address, date of property viewing with the real estate advisor

B.

Direct marketing information about the services of the Otthon Centrum Network and companies belonging to the Otthon Centrum group via phone, email, or electronic newsletters, especially

- information related to financial products/services brokered by HC Center Ltd.

- information about valuation services provided by Otthon Centrum Solutions Ltd. or opportunities related to ordering energy certificates through it.

- information related to investment and/or insurance products brokered by OC Finance Insurance Brokerage Ltd.

Article 6 of the GDPR

(paragraph 1 a.)

- the data subject's consent

the client's name, phone number, email address, property search data

- Otthon Centrum Franchising Ltd. and

- HC Center Ltd., and its subcontractors engaged in financial service brokerage under a contractual relationship, and

- Otthon Centrum Solutions Ltd. and its subcontractors engaged in related activities under a contractual relationship

- OC Finance Insurance Brokerage Ltd. and its subcontractors engaged in brokerage activities under a contractual relationship

Customer satisfaction inquiries, questions to refine customer needs sent via email and/or phone

Article 6 of the GDPR

(paragraph 1 a.)

- the data subject's consent

- name

- email address

- phone number

- property parameters

- answers to questions qualifying customer needs

- answers to customer satisfaction questionnaires

- Otthon Centrum Franchising Ltd., and

- the Franchise Partner and the real estate advisor in a contractual relationship who is directly connected with the client

Market research, market analyses, creation of statistics

Article 6 of the GDPR

(paragraph 1 a.)

- the data subject's consent

property data, data related to the sale of the property (e.g.: advertised price, sale price, etc.)

- Otthon Centrum Franchising Ltd. and

- Otthon Centrum Solutions Ltd.

3. Data Transfer

The Otthon Centrum Network only transfers the client's personal data in the event of civil legal claims arising from circumventing the Otthon Centrum Network during a property sale, specifically to a lawyer or law firm appointed by it or the Franchise Partner, or to a debt collection agency.

The Otthon Centrum Network may transfer the client's personal data to the property seller upon explicit request or in the case of making a purchase offer or during a sale transaction.

4. Duration of Data Management

The duration of data management for enforcing the Otthon Centrum Network's legitimate civil legal claims is three years from the date of the last property viewing. Thereafter, the data controller deletes the client's data.

Otthon Centrum Franchising Ltd. will delete the client's data if the client states they no longer wish to use the service and all properties they have viewed have been purchased by another client.

Data management based on the client's voluntary consent (see objectives listed in section 2.B) lasts until the withdrawal of consent, but not longer than two years from the date of the last property viewing. Thereafter, the data controller no longer uses the client's data for the consent-related purpose.

5. Data Processors

Data processors are natural or legal persons who manage personal data on behalf of the Data Controller within a contractual relationship. The Otthon Centrum Network uses data processors in the course of data management. Data processors do not make independent decisions and are authorized to act solely based on the contract with the Data Controller and the instructions received.

The following persons may be data processors in relation to the services and data management referenced in this notice:

- Those assisting in the operations of the Otthon Centrum Network in connection with Otthon Centrum Franchising Ltd., Otthon Centrum Solutions Ltd., the Franchise Partners, HC Center Ltd., or OC Finance Insurance Brokerage Ltd., including real estate advisors, office managers, administrative staff, mortgage brokers, insurance brokerage subcontractors, appointed appraisers, software providers.

6. Rights of the Data Subjects

Our clients are entitled at any time to request information about the personal data managed by the Otthon Centrum Network that pertains to them, and they may request the correction of incorrect data or the modification of data in the event of changes.

Our clients may at any time prohibit the further use of their personal data for purposes where the basis of data management was their voluntary consent, by sending a letter to Otthon Centrum Franchising Ltd. (1023 Budapest, Lajos utca 28-32) or an email to ugyfelszolgalat@oc.hu. They are also entitled to object to data management necessary for the enforcement of the legitimate interests of the Otthon Centrum Network.

Our clients may opt out of further newsletters, offers, and solicitations by clicking the unsubscribe link found at the bottom of the emails we send. Please note that if our client wishes to stop receiving further email newsletters, offers, or other solicitations, they must unsubscribe for all email addresses they have provided.

7. Remedies

The client can address any questions, observations, 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 the event of a complaint regarding the handling of their data, the client may submit a petition to the National Authority for Data Protection and Freedom of Information, or they may initiate a lawsuit at the court of jurisdiction based on their residence or place of stay.