DATA management INFORMATION AND data protection regulations
By issuing the present Data Protection Regulations,
Marina-Part Promenade Real Estate Development Ltd. (Ingatlanfejlesztő Kft.) (seat:1132 Budapest, Visegrádi u.78., Commercial Register Number: 01-09-861397, hereafter referred to as: Data Manager) hereby meets its preliminary information obligation related to the management of personal data and stipulated in Article 20 of Act CXII of 2011 on Informational Self-determination and Freedom of Information (hereafter referred to as “Info Act”).
Concerned party: any natural person, identified or, directly or indirectly, identifiable on the basis of specific personal data;
Personal data: any data associable with the party concerned (in particular, his/her name and personal identifier and any one or more information characteristic of the person’s physical, physiological, mental, economic, cultural or social identity) and any conclusion that can be drawn from the data regarding the party concerned;
Consent: voluntary and explicit declaration of the concerned party’s will expressed on the basis of proper information, furthermore, the party’s consent unambiguously granted regarding the handling of his/her personal data, without limitation or limited to certain specific procedures;
Objection: declaration made by the concerned party, announced to raise objection to handling his/her personal data and to request termination of such data handling or erasure of the processed data;
Data Manager: any natural person or any organization with or without legal personality who/which determines, individually or together with other persons, the purpose of data management, makes and implements or has a competent data processor implemented, the decisions related to the data handling process (including the assets used for such purpose);
Data management: irrespective of the actually applied process, any operation or the totality of operations carried out using the data, with particular regard to the collection, entering, recording, systematization, storage, alteration, utilization, retrieval, forwarding, disclosure, coordination or connection, blocking, erasure or destruction of the data, furthermore prevention of further use of the data, making of photos, video or audio recording or archiving of physical characteristics (e.g. finger or palm print, DNA sample, identification with iris recognition) suitable for the identification of the person;
Data erasure: making the data unrecognizable in a way that prevents its restoration.
Principles of data management
Personal data may be handled exclusively for some specific purpose, for exercising certain rights and meeting certain obligations. In each phase, the data management process shall be compatible with the purpose of data management and the data shall be recorded and handled in a fair and legal manner.
Personal data shall be managed only if it is essential for the implementation of the purpose of data management and is suitable for achieving such purpose. Personal data may be handled only to the extent and for the time needed to achieve the purpose.
In the course of data management, the personal data shall retain its quality as such until its connection with the party concerned can be restored. The connection can be reinstated with the party concerned if the Data Manager is in possession of the technical conditions needed for such reinstatement.
The Data Manager shall proceed in accordance with the data security provisions specified in Article 7 of the Info Act.
Purposes of data management
Purpose of data management: procurement or renting of real estates shown in the marinabay2.hu website, making the customers interested in using other related services and receiving our newsletters acquainted with the real estates and the services, maintaining contacts with and recalling the customers, responding to their questions, mailing of newsletters and accomplishing any related administrative task.
Legal basis of data management:
According to Section 1(a) of Article 5 of Info Act, personal data may be handled after having obtained consent from the party concerned thereto. According to the same Article, the party concerned (hereafter referred to as “the Party”) shall give voluntarily the following data for the purpose of maintaining customer relationship:
› email address
› phone number
› address of domicile
› forename, surname.
The Party shall give his/her consent to the data management by voluntary disclosure of the above mentioned data, using our website (www. marinabay2.hu). The extent of such consent comprises operations including collection, entering, recording, systematization, storage, alteration, utilization, erasure and destruction of the data.
Any legal declaration containing consent given by an adolescent person above the age of 16 shall be valid without obtaining preliminary agreement from or subsequent approval by his/her legal representative.
Eligibility of the person giving consent shall not be checked on the basis of the data (name, email address) disclosed voluntarily to the Data Manager. In case of using services by using the website (www. marinabay2.hu), the Data Manager shall consider the approval requested from the legal representative as granted.
The Party using the website (www. marinabay2.hu) shall voluntarily disclose the above mentioned data to the Data Manager by marking the “recall requested” or “respond in writing” fields in the registration sheet and by filling the hard copy form accessible only by the Data Manager. The Data Manager shall assume unlimited strict confidentiality obligation in respect to the personal data handled by it and shall not disclose such information to third parties contrary to the consent given by the Party.
Information about the data management
Pursuant to Article 20 of Info Act, in order to ensure that the consent to data management is given voluntarily, explicitly and unambiguously and is based on proper information, Data Manager shall, in each case and in advance, furnish the Party with clear and detailed explanation of the present Regulation as to expound every detail related to the management of the Party’s personal data. The Party can learn about the present Regulation by reading the website (www. marinabay2.hu) and can indicate acceptance of the same by ticking the four boxes appearing beside the Regulations.
In the course of using the Data Manager’s website, the technical information sent by the Party’s browser shall be stored in the Server Log files. The website (www. marinabay2.hu) uses anonymous visitor identifier (cookies) which is a unique series of signals suitable for identification or for storing profile information set by the service providers in the computers of the visitors. Since such series of signals are incapable of identifying the customer (i.e. the visitor) because this function does not result in storing of the entire IP address, they are not suitable but for recognizing the visitor’s computer. It is not necessary to give any name, email address or any other personal information because the service provider does not expect the visitor to disclose any data and the exchange of data takes place, in fact, between the computers.
Mailing of newsletters. Data management for marketing purposes
Data Manager uses the data for sending newsletters and marketing materials to Parties who have given their explicit and unambiguous consent thereto. In meeting its legal obligation, the Data Manager notifies the National Data Protection and Freedom of Information Authority of its data management activities and performs the handling of data in compliance with such statutory provisions.
The template of the website (www. marinabay2.hu) comprises the voluntary declaration made by the Party to confirm his/her willingness to receive direct marketing newsletters sent to the email address the Party had provided. The approving declaration can be given by ticking the corresponding box in the registration template; such consent can be withdrawn at any time, without limitation or giving reasons, free of charge. In that case, the Party’s email address shall be deleted from the records without delay and no further newsletter shall be sent to that address.
Any Party who shows, in person or through the phone, any interest in the real estate shown in the website (www. marinabay2.hu), shall fill a separate form to give consent to the Data Manager for the subsequent use of his/her data (email address, forename/surname, phone number).
Data Manager shall keep a record to enter the data of persons giving their consent and declaration. The personal data entered into such record can be handled only according to the provisions specified in the declaration, until withdrawal of the latter. We provide possibility for stating the announcement of the consent and the forbiddance of sending newsletters, in person, by mail or email. Data Manager shall delete the data not later than 30 (thirty) calendar days after having received the Party’s relevant request.
The Party can raise objection against handling of his/her data in accordance with the provisions of Article 21 of the Info Act.
Period of data management:
The Party’s personal data shall be handled as of the date of disclosure of the data until its erasure by the Data Manager. The interested Party can request erasure of his/her personal data at any time during the data handling period.
The Party can request the Data Manager:
- a) to give information about the handling of his/her personal data,
b) to make amendments to his/her personal data, and
c) to erase or block his/her personal data, except for cases of mandatory data management processes.
Upon request from the Party, Data Manager shall give information about the Party’s data handled by it or processed by a data processing entity commissioned by Data Manager, about the origin of the data, the purpose, legal ground and period of data management, the name, address of the data processor and its activities related to data management, the circumstances and outcome of any data protection incident and the measures taken to avert such incident, furthermore, in case of forwarding the Party’s personal data, the legal ground and addressee of such forwarding. Data Manager shall, within the shortest possible time but not later than 25 days after having received the Party’s relevant request, provide information, written in plain language. The information shall be given free of charge, provided that the requesting Party has not yet submitted, during the subject year, to the Data Manager any request for information regarding the same scope of issues. In other cases, reimbursement of the related expenses can be claimed.
The Data Manager can deny disclosure of information to the Party only in cases specified in Article 9(1) and Article 19 of the Info Act.
In case of denying the information, the Data Manager shall notify, in writing, the Party of the provisions of the relevant Act giving ground for such denial. In case of such denial, Data Manager shall inform the Party about the possibilities for seeking legal remedies from the court or the competent Authority. Data Manager shall notify the Authority of the rejected requests once a year, not later than the 31st of January of the year following the subject year.
If a personal data is incorrect and the correct personal data is available to the Data Manager, the Data Manager shall correct the incorrect personal data.
Data Manager shall erase the Party’s personal data if the data is handled by tort or the Party requests, in conformity with Article 14(a) of the Info Act, such erasure or the purpose of data management ceased to exist or the period established by law for keeping the data in files expired or the National Data Protection and Freedom of Information Authority ordained such erasure or the data is handled incompletely or erroneously (and this situation can not be remedied legally), unless such erasure is excluded by law.
Data Manager shall block the Party’s personal data if the Party requests them to do so or if the available information allows for assuming that the erasure would violate any lawful interest of the Party. The blocked personal data shall be handled only until the existence of the data management purpose which excluded erasure of the personal data.
Data Manager shall mark personal data handled by it provided that the Party disputes the correctness or accuracy of such data but incorrectness or inaccuracy of the data can not be established unequivocally.
If Data Manager does not meet the Party’s request for amendment, blocking or erasure, the factual reasons and legal justification of the denial of such amendment, blocking or erasure shall be disclosed in writing or, with the Party’s consent, via email within 25 days of receiving the Party’s request. In case of rejection of the request for amendment, blocking or erasure of the data, Data Manager shall notify the interested party of the possibilities available for seeking legal remedies from the court or the competent Authority.
In case of any violation of law, the Parties may refer the case to the Data Protection Officer in accordance with the provisions of the Info Act or can bring the issue before the court. The detailed legal regulations governing such situations or applicable to the Data Manager’s obligations are stipulated in the Info Act.
Legal remedies can be sought at or complaints can be submitted to the National Data Protection and Freedom of Information Authority:
Seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Should the Party disagree with the decision made by Data Manager in compliance with the provisions of Article 21(2) of the Info Act or if Data Manager fails to observe the deadline specified in the same Article, the Party may bring the case before the court within 30 days of the date of disclosure of such decision or the last day of the deadline, as stipulated in Article 22 of the Info Act. The litigation shall be adjudged by the court. The litigation can be initiated, upon discretion of the Party, at the court competent according to the Party’s address of domicile or habitation.
The Data Manager reserves the right to enter amendments to the present data management leaflet by unilateral decision. Data Manager shall publish the currently valid version of the present data management information in its webpage. The Party shall accept the content of the amended data management information implicitly, by availing himself of the services offered by the Data Manager.