Data Management Information for Clients Assigning and Viewing Property Searches

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 group

- 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

- 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.

- 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.

The members of the Otthon Centrum Network, based on the agreement between them, qualify as joint data controllers, which means that the purpose and tools of data management specified in this data management information are determined jointly.

The data management practice of the Otthon Centrum Network is based on the European Union's General Data Protection Regulation (GDPR) 2016/679, and the 2011 Act CXII on Informational Self-Determination and Freedom of Information.

2. The purpose, legal basis, scope of managed data, and those with access

Article 6 of the GDPR

(paragraph 1 b.)

- data management necessary for the performance of a contract

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

- Otthon Centrum Franchising Ltd. and

- HC Center Ltd., and its subcontractors engaged in the mediation of financial services

- Otthon Centrum Solutions Ltd. and its subcontractors engaged in the activity

- OC Finance Insurance Brokerage Ltd. and its subcontractors engaged in the mediation activity

- name

- email address

- phone number

- property parameters

- responses to questions qualifying client search needs

- responses to client satisfaction questionnaires

Purpose of data management

Legal basis for data management

Scope of managed data

Who can access the data?

A.

providing real estate brokerage services based on a contract to the client

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

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 in a contractual relationship who has the property that matches the client's search in their portfolio, or advertises such a property, or has the specific property viewed by the client in their portfolio, or advertises it.

enforcement of the Otthon Centrum Network's legitimate civil legal claims in case of circumventing the real estate broker

Article 6 of the GDPR

(paragraph 1 f.)

- enforcement of the data controller's legitimate interests

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

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 prescribed by the 2017 Act LIII on the Prevention and Impediment of Money Laundering and Terrorism Financing (Pmt.)

the client's name, birth name, address, mother's name, place of birth, date of birth, nationality, type and number of identification document, residence in case of a foreign private individual

The client's personal data can be accessed by the Otthon Centrum Franchising Ltd. and the Franchise Partner who is or was in a contractual relationship with the client.

B.

direct marketing information about the services of the Otthon Centrum Network and the companies belonging to the Otthon Centrum group, especially

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

- information about valuation services provided by Otthon Centrum Solutions Ltd. or about the opportunity to order an energy certificate through it.

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

Article 6 of the GDPR

(paragraph 1 a.)

- the subject's consent

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

Client satisfaction inquiries, questions aimed at clarifying client needs sent via email and/or phone

Article 6 of the GDPR

(paragraph 1 a.)

- the subject's consent

- Otthon Centrum Franchising Ltd., and

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

Market research, market analyses, and the preparation of statistics

Article 6 of the GDPR

(paragraph 1 a.)

- the subject's consent

property data, search parameters, and data related to property sales (e.g., advertised price, sale price, etc.)

- Otthon Centrum Franchising Ltd. and

- Otthon Centrum Solutions Ltd.

3. Data Transfer

The Otthon Centrum Network transfers client data to the Financial Information Office within the framework of the National Tax and Customs Administration in cases specified by Pmt.

The Otthon Centrum Network transfers client personal data exclusively in the event of enforcing civil legal claims arising from circumventing the Otthon Centrum Network, specifically to the attorney or law office commissioned by it or the Franchise Partner, or to a debt collection company.

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

4. Duration of data management

According to Pmt., the duration of data management is 8 years from the termination of the business relationship.

In the case of data managed based on a contractual relationship with the client, the duration of data management is up to 5 years from the termination of the business relationship.

In the case of data management based on the client's voluntary consent (see the purposes listed in section 2.B), the duration of data management is until the withdrawal of consent, but no longer than 2 years from the day of the last property viewing. After this period, the data controller no longer uses the client's data for the consent-related purpose.

5. Data Processors

Data processors qualify as natural or legal persons who manage personal data related to the subjects under a contractual relationship with the Data Controller. The Otthon Centrum Network engages data processors in the course of data management. Data processors do not make independent decisions; they are authorized to act solely according to the contract with the Data Controllers and the instructions received.

The data processors mentioned in this information regarding services and data management may include the following individuals:

                 - Other collaborators, assistants in performance (e.g., real estate advisors, office managers, administrative staff, mortgage brokers, insurance brokers, appointed appraisers, software providers) who are in a contractual relationship with Otthon Centrum Franchising Ltd., Otthon Centrum Solutions Ltd., the Franchise Partners, HC Center Ltd., or OC Finance Insurance Brokerage Ltd.

6. Rights of the subjects

Our clients are entitled at any time to request information about the personal data managed by the Otthon Centrum Network pertaining to them, to request the correction of incorrect data, and to modify them in case of changes.

Our clients can forbid the further use of their personal data for any purpose where the legal basis for 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.

Our clients, by clicking the unsubscribe link at the bottom of the newsletters and offers we send, are entitled to forbid the sending of further newsletters, offers, and inquiries. We draw attention to the fact that if our client wishes to prohibit the sending of further email newsletters, offers, and other inquiries, they must unsubscribe for all email addresses provided by them.

7. Legal remedies

The client may approach the Otthon Centrum Network with any questions, remarks, or complaints related to data management 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 the management of their data, the client may file a complaint with the National Authority for Data Protection and Freedom of Information or initiate legal proceedings at the court competent according to their place of residence (place of stay).