Privacy Policy

Table of contents

1. Purpose of the Privacy Policy

This Privacy Policy expresses the strong commitment of XXX (hereinafter: Data Controller) to privacy rights and data protection.
The Data Controller shall use the personal data in its possession with the utmost care, in accordance with this Privacy Policy,

– 2003. Act C of 2009 on the

– 2001. Act CVIII of 2008 on Certain Issues of Electronic Commerce Services and Information Society Services

– 2011. Act CXII of 2008 on the Right of Informational Self-Determination and on Freedom of Information

Directive 2002/58/EC of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications)

– and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016

provisions of the Decree.

Please read this document carefully and use our services only if you agree with all of its points and accept them as binding on you.

Please note that this policy only applies to the cookie management of the respective website (marbellahome.hu domains and their subdomains).

If you click on an external link on the website, please find and read the website’s own rules as well.

The Privacy Policy is available at http://marbellahome.hu/adatkezelesi-tajekoztato/ address at all times.

The Data Controller reserves the right to modify this information at any time.

The Data Controller is committed to the protection of the personal data of its clients and partners, and considers it of utmost importance to respect the right of its clients to informational self-determination.

The Data Controller handles personal data confidentially and takes all security, technical and organizational measures that guarantee the security of the data.

2. Data of the Data Controller

Name: Bindics Law Firm

Headquarters: 1112 Budapest, Beregszász út 109.

Tax number: 18195565-1-43

Chamber ID: 36057630 (Budapest Bar Association)

Phone: +36 30 331 5885

E-mail: bindics@bvo.hu

2.1 Data Protection Officer

The Data Controller shall not carry out any activity that would justify the appointment of a Data Protection Officer.

3. Scope of processed personal data

3.1. Technical details

The Data Controller selects and operates the IT tools used for the processing of personal data in the course of providing the service in such a way that the processed data:

– accessible to authorised persons (availability);

– its authenticity and authentication are ensured (credibility of data processing);

– its unchanged can be verified (data integrity);

– be protected against unauthorized access (data confidentiality).

The Data Controller shall take appropriate measures to protect the data against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as accidental destruction.

The Data Controller shall ensure the protection of the security of data processing with technical, organisational and organisational measures that provide a level of protection appropriate to the risks arising in connection with data processing.

The Data Controller shall maintain confidentiality during data processing:

– protects the information so that only those who are entitled to access it can access it;

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

– availability: ensures that the authorised user has access to the information they want when they need it and that the tools are available;

– not pass on the incoming data to third parties;

– data processing takes place in its own system.

3.2 Cookies

3.2.1 Functions of cookies

Cookies are small text files that a website can use to make the user experience even more efficient.

According to the law, we may store cookies on your device if it is absolutely necessary for the operation of our website.

We need your permission to use all other types of cookies. This website uses various cookies.
Some of the cookies that appear on our website are placed by our third-party service providers.

You can change or withdraw your consent to the use of Cookies on our website at any time.

Cookies collect information about visitors and their devices;

– remember the individual preferences of the visitors, which are (may) be used, e.g. when using online transactions, so they do not have to be re-typed;

– facilitate the use of the website;

– provide a quality user experience;

– and participate in the collection of some visitor statistical information.

In order to provide a customized service, a small data packet, a so-called cookie, is placed on the user’s computer and read back during a subsequent visit.

If the browser returns a previously saved cookie, the provider managing the cookie has the option to link the user’s current visit with the previous one,
but only with respect to its own content.

Some of the cookies do not contain personal information that can be used to identify an individual user, some of them contain a secret, randomly generated sequence of numbers that is stored on the user’s device and ensures the user’s identification.

3.2.2 Strictly Necessary, Session SESSION Cookies/Cookies

Essential cookies help us make our website usable by enabling basic functions such as page navigation and
access to secure areas of the website. The website cannot function properly without these cookies.

The purpose of these cookies is to enable visitors to browse the marbellahome.hu website fully and smoothly, to use its functions and the services available there.

The validity period of this type of cookies lasts until the end of the session (browsing), when you close the browser, this type of cookies is automatically deleted from your computer,
or from another device you use to browse.

3.2.3 Third-party cookies/cookies (Analytics/Statistics)

The websites placed on the marbellahome.hu and its subdomains also use Google Analytics as a third-party cookie.

By using the Google Analytics statistical service, the Data Controller collects information about how visitors use the websites and how visitors interact with the website.

The data is used for the purpose of improving the website and the user experience.

These cookies also remain on the visitor’s computer or other device used for browsing, in its browser, until they expire, or until the visitor deletes them.

3.2.4 Legal basis for cookie/cookie management

The legal basis for the processing of cookies is the consent of the website visitor, based on Article 6 (1) a) of the relevant Regulation.
If you do not accept the use of cookies, certain functions of the website listed in section 3.2.3 will not be available during the use of the website,
or some features may malfunction.

You can find more information about deleting cookies/cookies for the most common browsers at the following links:

Chrome: https://support.google.com/accounts/answer/61416?hl=hu

Firefox: https://support.mozilla.org/hu/kb/sutik-informacio-amelyet-weboldalak-tarolnak-szami

Internet Explorer: https://support.microsoft.com/hu-hu/help/17442/windows-internetexplorer-delete-manage-cookies#ie=ie-11

Safari: https://support.apple.com/hu-hu/HT201265

Edge: https://support.microsoft.com/hu-hu/help/10607/microsoft-edge-view-deletebrowser-history

Opera: http://help.opera.com/Windows/10.20/hu/cookies.html

3.2.5 List of cookies/cookies on the Data Controller’s website

Cookies necessary for the operation of websites

Cookies are essential for the use of the website and enable the use of basic functions of the website.

Without these, many of the site’s features will not be available.

The session does not collect any personal information.

Cookies to improve your experience

Cookies collect information about the use of the website and serve to improve the user experience.

The session does not collect any personal information.

Session cookies

Cookies store the visitor’s location.

Expiration time: Maximum 2 hours or closing the browser.

Google.com and Gstatic.com

Name: _ga and _gid

The cookie/cookie is used to collect website statistics and track conversion rates.

These cookies/cookies allow our websites to remember how the website works or is displayed, such as information that changes your preferred language or the region in which you are located.

_ga: We use Google Analytics cookies/cookies to measure traffic on our website. A single text bar is saved to identify the browser, the timestamp of interactions, and the browser/source page that led the user to our website.

Expiration date: 2-10 years

It does not collect any personal information.

WordPress

Cookies/cookies that are strictly necessary for the operation of the website engine are used to maintain the user’s wp-admin configuration. It is created only when accessing the admin interface.

Name: wp-settings-{user_id}

Expiration date: 1 year

It does not collect any personal information.

WordPress

The value of the website’s cookie/cookie consent.

Name: cookie_notice_accepted, cookielawinfo-checkbox-necessary, cookielawinfo-checkbox-non-necessary

Expiration date: 1-2 days, 1 month

Value for viewing the privacy policy of the website.

Name: viewed_cookie_policy

Expiration date: 1 year

It does not collect any personal information.

4. General data processing guidelines, name, use, legal basis and retention period of data processing

The data processing of the Data Controller’s activities is based on voluntary consent and statutory authorisation.
In the case of data processing based on voluntary consent, the data subjects may withdraw this consent at any stage of the data processing.

In some cases, the handling, storage and forwarding of a range of the data provided is required by law, of which we notify our customers separately.

We would like to draw the attention of the Data Controller to the fact that if they do not provide their own personal data, the data provider is obliged to obtain the consent of the data subject.

4.1 Data related to online administration

Personal data requested during contact:

Name (required field)

Email address (required field)

Purpose of data processing: The data is requested for the purpose of contacting us.
Legal basis of data processing: voluntary consent.
Retention period: the duration of the business relationship or a deletion request.

4.2 Data related to telephone administration

Personal data requested during contact:

Name (required)

Email address (optional, optional)

Phone number (optional, optional, to initiate a callback)

Purpose of data processing: The data is requested for the purpose of contacting us.

Legal basis of data processing: voluntary consent.

Retention period: the duration of the business relationship or a deletion request.

4.3 Handling of consumer complaints

If you file a consumer protection complaint, the processing of data and the provision of data are essential for administration.

Requestable data: Name, E-mail address, phone number, complaint

Purpose of data processing: administration of consumer protection complaints.

Legal basis of data processing: voluntary consent.

Retention period: according to the Consumer Protection Act, the current year + 5 years

5. Physical storage locations of data

Your personal data (i.e. data that can be linked to your person) may be processed by us in the following ways:

On the one hand, in connection with maintaining an internet connection, the computer, browser program, internet address you use,
technical data related to the visited pages are automatically generated in our computer system and devices,

You may also provide your name, contact details or other details if you wish to contact us when using the website.

Technical data recorded during the operation of the system:
data of the computer of the data subject logged in, which are recorded by the systems located in the marbellahome.hu and its subdomains as an automatic result of technical processes.

6. Data transfer, data processing, scope of data recipients

Within the framework of its business activities, the Data Controller uses the following data wall workers:

Company: Expertinit Ltd.
Headquarters: 1096 Budapest, Sobieski János utca 25/B.
Tax number: 14145049-2-43
EU VAT number: HU14145049
Company registration number: 01-09-351119
Statistical number: 14145049 6209 113 01

Availability:
Phone: Gergely Tóth +36 20 527 8001
E-mail: bajvan@bajvan.hu
Website: https://bajvan.hu

Scope of data obtained: the content of marbellahome.hu domains and the websites located on its subdomains, e-mails received by e-mail addresses based on these domains.

Google Analytics:

Google Inc., Mountain View, California, USA

Scope of data obtained: anonymized, non-personally identifiable IP addresses of visitors to the marbellahome.hu domains and websites located on its subdomains.

Facebook:

Facebook Inc.

Menlo Park, California, USA

Privacy Policy: https://www.facebook.com/about/privacy/update

Scope of data obtained: username, comment

7. Rights and enforcement options of the Data Subject

The data subject may request information about the processing of his or her personal data, as well as request the rectification of his or her personal data, or – in accordance with the mandatory data processing
– may exercise their right to data portability and objection in the manner indicated at the time of recording the data, or at the above contact details of the Data Controller .

7.1 Right to information

The controller shall take appropriate measures to ensure that the data subjects are provided with the data subject to the processing of personal data in accordance with Articles 13 and 14 of the GDPR
all that information and each information referred to in Articles 15 to 22 and 34 shall be provided in a concise, transparent, intelligible and easily accessible form, in a clear and plain
worded.

7.2 Data subject’s right of access

The data subject shall have the right to receive feedback from the Data Controlleras to whether the processing of his/her personal data is in progress,
and if such processing is in progress, you have the right to access your personal data and the following information:

– the purposes of the processing;

– the categories of personal data concerned;

– the recipients or categories of recipients to whom the personal data have been or will be disclosed, including, in particular, recipients in third countries or international organisations;

– the planned period for which the personal data will be stored;

– the right to rectification, erasure or restriction of processing and the right to object;

– the right to lodge a complaint with a supervisory authority;

– information on data sources;

– the fact that automated decision-making is carried out, including profiling, as well as comprehensible information on the logic used and the significance of such processing and the likely consequences for the data subject.

The Data Controller shall provide the information within a maximum of one month from the submission of the request.

7.3 Right to rectification

The data subject may request the correction of inaccurate personal data processed by the Data Controller and the completion of incomplete data.

7.4 Right to erasure

The data subject is entitled to the deletion of personal data concerning him or her without undue delay at the request of the Data Controller if one of the following reasons exists:

– personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

– the data subject withdraws his/her consent on which the data processing is based and there is no other legal basis for the data processing;

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

– the personal data were unlawfully processed;

– the personal data must be erased in order to comply with a legal obligation imposed by EU or Member State law applicable to the Data Controller;

– the personal data was collected in connection with the provision of information society services.

The deletion of data cannot be initiated if data processing is necessary:

– for the purpose of exercising the right to freedom of expression and information;

– compliance with an obligation under EU or Member State law requiring the processing of personal data applicable to the Data Controller,

– or for the performance of a task performed in the public interest or in the exercise of official authority vested in the Data Controller;

– for public health purposes, archiving, scientific and historical research or statistical purposes, in the public interest;

– or to establish, exercise or defend legal claims.

7.5 Right to restriction of processing

At the request of the data subject, the Data Controller shall restrict data processing if one of the following conditions is met:

– the data subject disputes the accuracy of the personal data, in which case the restriction applies to the period enabling the accuracy of the personal data to be verified;

– the processing is unlawful and the data subject opposes the erasure of the data and instead requests the restriction of their use;

The Data Controllerno longer needs the personal data for the purpose of data processing, but the data subject requires them for the establishment, exercise or defence of legal claims;

– or the data subject has objected to the processing; in this case, the restriction shall apply for the period until it is established whether the legitimate reasons of the Data Controller take precedence over the legitimate reasons of the data subject.

Where processing is subject to restriction, personal data may only be processed, with the exception of storage, with the consent of the data subject or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.

7.6 Right to data portability

The data subject shall have the right to analyse the personal data relating to him or her provided by him or her to the Data Controller ,
in a commonly used machine-readable format and transmit this data to another Data Controller.

7.7 Right to Object

The data subject has the right to object, on grounds relating to his or her particular situation, at any time to the processing of his or her personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller, or to the processing necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, including profiling based on the aforementioned provisions.
In the event of an objection, the Data Controller may no longer process the personal data, unless it is justified by compelling legitimate reasons,
which override the interests, rights and freedoms of the data subject, or which are in order to establish, exercise or
protection of the Labour Market.

7.8 Automated decision-making in individual cases, including profiling

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling,
which would produce legal effects in respect of him or similarly affect him to a significant extent.

7.9 Right of withdrawal

The data subject has the right to withdraw his consent at any time.

7.10 Right of access to the courts

In the event of a violation of his rights, the data subject shall be entitled to: You may turn to court against the Data Controller. The court proceeds in the case out of turn.

Data protection authority procedure Complaints can be lodged with the National Authority for Data Protection and Freedom of Information:

Name: National Authority for Data Protection and Freedom of Information

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

Mailing address: 1530 Budapest, Pf.: 5.

Phone: +36 1 391-1400

Fax: +36 1 391-1410

E-mail: ugyfelszolgalat@naih.hu

Website: http://www.naih.hu

8. Miscellaneous

Information on data processing not listed in this information will be provided at the time of data recording.

We would like to inform our clients that the court, the prosecutor, the investigating authority, the misdemeanour authority, the administrative authority, the National Authority for Data Protection and Freedom of Information, the National Bank of Hungary, or other bodies authorised by law may contact the Data Controllerfor the purpose of providing information, disclosure and transfer of data, or the provision of documents.

The Data Controller shall disclose personal data to the authorities – if the authority has specified the exact purpose and scope of the data – only to the extent that is strictly necessary for the achievement of the purpose of the request.

(This Privacy Policy has been prepared on the basis of the recommendation of the Budapest Chamber of Commerce and Industry.)

ES-Marbella, HU-Budapest, 2021. 23 September