PRIVACY POLICY

valid from July 2023

Responsible party and your rights as the data subject

1. Responsible Entity

The responsible entity (Controller) for the data processing regulated in this Privacy Policy is FIS Hungary Kft. (hereinafter “we” or “us”). Our contact details are:

Company Name: FIS Hungary Kft.
Address: Szentkirályi utca 3, fszt. 1, 1088 Budapest
e-mail: office@fis-vienna.com

2. Your rights as a data subject

You have the right to information about the processing of your personal data (for example, the origin of this data, the purpose of processing, and the modalities of data processing). Furthermore, under certain conditions, you are entitled to object to the future processing of your data, as well as the right to restrict the use or the deletion of said data. Finally, you may at any time stop the sending of advertising material or the execution of market research or commercial communications.

In summary, you have a right to

– Information, – Correction,
– Deletion (or request to be forgotten),
– Restriction of processing,
– Data portability,
– Object to the processing of your personal data,
– Complaint to supervisory authorities.

In addition, you have the right, at any time, to object to the processing of your personal data for direct marketing purposes. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.

According to Art. 7 III of the EU General Data Protection Regulation (hereinafter “GDPR”), you may at any time revoke your initial consent towards us. Once the consent is revoked, we will no longer continue to process the data.

Please note that your right to the deletion of your data is subject to certain restrictions. For example, we do not have to or are not allowed to delete data that we are required to retain due to legal retention periods. Data that we need to assert, exercise or defend due to legal claims are also excluded from your right of deletion.

If you have a complaint about the way we process your data, you have the recourse to a supervisory authority, in particular in the member state of your residence, workplace or the place of the alleged breach. We reserve the right to disclose information about you if we are required to do so by law enforcement bodies or other lawful authorities. Legal basis: Art. 6 I sentence 1 lit. c GDPR (legal obligation).

Overview of our data processing procedures

Our Privacy Policy is structured as follows and provides you with an overview of the following data processing procedures:

I. You visit our company web presence on the Internet
II. You apply at your own initiative or in response to a job advertisement
III. Storage and deletion of your data

I. Collection and processing of personal data when visiting our company web presence on the Internet

We only process personal data if the personal data is sent to us via the contact forms on our company web presence. In this regard, personal data is only processed once explicit consent has been given to us for the processing of your data or if the processing is permitted by legal regulations. For certain services that we offer on our company web presence, we require a minimum amount of data. We have marked mandatory information with an “asterisk”. Without the mandatory information, we are unable to provide our services.

1. What data do we process from you (hereinafter referred to as “you” or “user”)?

In the context of your usage of our company web presence, we process the following personal data:

The e-mail address, first name, last name, title, address, telephone number and property data provided by you in the case of the services offered on our company web presence for example, in the context of contact enquiries and newsletter mailings, as well as a market price determination (Valuation), hereinafter referred to as “Data ” or “ Personal Data ”.

Please refer to the description of the usage-related data processing in connection with the use of cookies and other tracking technologies in the “Cookie Policy” of:

Company Name: FIS Finance & Investment Services Group (the “Group”)
E-mail: office@fis-vienna.com

You will find the Cookie Policy at the bottom of our company web presence.

2. Purpose of the processing and legal basis thereof

We process your data for the following purposes:

Fulfilment of contact requests (legal basis is the fulfilment of the contract, as well in case of the transfer of user data to other license partners of the Group (for the definition please see section 3 below) your consent;
Contact by telephone by us (legal basis is the fulfilment of the contract or, in the case of the use of the telephone number for advertising purposes, your consent);
Sending out an e-mail newsletter containing our real estate offers as well as self and third-party advertising to the extent permitted by law or based on the consent given (the legal basis is either your consent or our legitimate interest in direct marketing, as long as the marketing is carried out in compliance with data protection and competition law requirements)

In summary:

The legal basis for the processing of personal data is Art. 6 I sentence 1 lit. a GDPR if the processing is based on consent, Art. 6 I sentence 1 lit. b DSGVO if the basis of the processing is a contractual (or possibly pre-contractual) relationship and Art. 6 I sentence 1 lit. f GDPR if the basis is our legitimate interest. If the processing of personal data is necessary for the fulfilment of a legal obligation to which we are subject, Art. 6 I sentence 1 lit. c GDPR serves as the legal basis.

If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing of your personal data carried out based on the consent until revocation. If the legal basis is the legitimate interest, you are also generally entitled to object to the processing of personal data relating to you at any time for reasons arising from your particular situation. In this respect, Art. 21 GPR applies.

3. Disclosure of your personal data

We will only pass on your personal data to third parties such as real estate agents, if this is necessary for the fulfilment of the contract, if the third party or we have a legitimate interest in the transfer, if there is a legal obligation or if you have given your consent. If data is transferred to third parties based on legitimate interest, this will be explained in this Privacy Policy.

If your contact request pertains to offers from other companies of the Group, we will transfer the personal data you entered in this case to the respective company from the Group with your prior consent or – if legally permissible – based on a so-called legitimate interest. We will not pass on your personal data beyond this. When we refer to the “Group ” in this Privacy Policy, we mean the companies belonging to the group of companies as well as the (master) license partners which are directly or indirectly contractually affiliated to this group of companies and to which we also belong.

4. Transfer of data to non-EEA countries

In addition to the above paragraph “Disclosure of your personal data”, the following applies:

Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed by the European Union and the recipient of the data (Art. 46 GDPR) unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree to additional measures with recipients to ensure an adequate level of data protection. Copies of the adequate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the necessary extent to protect trade secrets or other confidential information.

II. You apply on your own initiative or in response to a job advertisement

1. Purpose of the processing and legal basis

If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing carried out based on the consent until revocation. If the legal basis is the legitimate interest, you are also generally entitled to object to the processing of personal data relating to you at any time for reasons arising from your particular situation. In this respect, Art. 21 GDPR applies.

2. Disclosure of your data

We will only disclose your personal data to third parties such as inter alia real estate agents if this is necessary for the fulfilment of the contract, if we or the third party have a legitimate interest in the disclosure, if there is a legal obligation or if you have given your consent. If data is transferred to third parties based on legitimate interest, this will be explained in this Privacy.

3. Transfer of data to non-EEA countries

In addition to the above paragraph “Disclosure of your personal data”, the following applies:

4. Storage and deletion of your data

We retain your personal data for the time necessary to achieve the purposes for which data is collected, including any retention period required by law (e.g. retention of accounting records.)

In the context of application procedures that end without employment, your data is stored for six months for the purpose of documentation and then deleted or destroyed, this includes any additional documents provided to us in relation to the application process.

In the event that you provide us with express consent to retain your data for future applications, we will retain the relevant data for a longer period of time.

Data protection information for visiting the website and the Property Search App

This data protection information applies to the use of the website www.rosehill-living.hu (hereinafter referred to as “website” and is valid from July 2023 .

The following information applies to the website, unless expressly stated otherwise.

FIS Hungary Kft. in its function of responsible authority (hereinafter also referred to as “Company” informs its users that by using the website, personal data about them will be processed, in particular:

– personal data (e. g. e-mail address, first name, surname, title, address, telephone number – in the following “data” or “personal data”) provided by users at the time of registration on the website (e.g. in connection with contact requests); – personal data transferred from the user’s internet browser each time the user accesses the website and stored within log files, also known as server logs. This data comprises: IP address (Internet protocol address) of the accessing computer; name of the accessed site; date and time of access; related URL from which the user accesses the site; number of transferred data items; status report of successful access; session ID-number;

Purpose of processing

The Company, as a responsible authority, processes the personal data of website and property app users for the following purposes:

– Fulfilment of user’s requests (legal basis is contract performance and the legitimate interest of Company in transferring contact requests within the Group to the appropriate company. The above “Group” comprises the Company and its domestic and foreign associated companies and the (master) licensees affiliated with this group of companies);

– The forwarding of e-mail newsletters (website only) on the company’s own offers and advertising by the company or third parties to the legally permissible extent or based on consent. (Legal basis is either the consent or the legitimate interest of Company in direct marketing, providing this is in accordance with the data protection and competition rules);

– For the functionality and optimization of the Company website. (Legal basis is the legitimate interest of Company in continuously improving the quality of the website and property app and ensuring its ease of use);

– Analysis of the website for determining user behaviour and for interest-based advertising. (Legal basis is the consent.);

– Identification and possible blocking of users who have installed a so-called adblocker and who thereby block advertising. (Legal basis is the legitimate interest of Company of providing users who do not block advertising with wholly or partially web-financed offers);

– In order to prevent fraudulent activities or misuse on the website or in connection with the website and to observe the legal stipulations for secure websites. (Legal basis is the legitimate interest of Company in eliminating faults, ensuring system security and identifying unauthorised access attempts or accesses.)

The legal basis for the processing of personal data is GDPR Article 6(1)(a), if the processing is based on consent, Article 6(1)(b) if the basis for processing is a contractual relationship and Article 6(1)(f) if the basis is the legitimate interests of Company.

If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until revocation. If the legal basis is a legitimate interest, you are also entitled in principle to object to the processing of your personal data at any time for reasons arising from your particular situation. Article 21 GDPR applies in this respect.

Nature of supply of personal data and consequences of objection

The provision of personal data by users is voluntary. They may freely decide whether to make personal data available to Company and may subsequently revoke their consent to the processing of personal data which have already been made available. Revocation may mean that the Company website is no longer usable.

Access to data

The personal data is processed by Company and (in respect of individual items) particularly by Employees (permanent employees such as job-holders and independent property consultants) and consultants authorised to administer the website and property app and provide the associated services;

Third-party supplier companies (e.g. IT service providers, hosting providers, etc.) to which Company has outsourced processing services as part of a job processing agreement.

Information about the data

As the responsible authority we are able to provide information about your personal data. However, this information may only be given for the following reasons:

In the case of fulfilment of legal obligations or obligations arising from regulations and guidelines under national or European laws. For defense in court in the case of a legal dispute.

Disclosure of data

If your query relates to offers from other companies of the Group, Company transfers the personal data entered by you in this case to the respective company from the Group with your prior consent or on the basis of its legitimate interests. Other than this, your personal data will not be disclosed by Company.

Disclosure of data in non-EEA countries

Company will not transfer any personal data to non-EEA countries without your consent. The servers used by Company are located within the European Union. If your query relates to companies of the Company Group outside the European Union, we will transfer your data after obtaining your consent. In cases where personal data is transferred to countries that do not offer the same level of protection as within the European Union and you have not expressly agreed to the transfer of your data to those countries by way of your consent, Company will ensure that certain contractual obligations under applicable data protection law (including the execution of standard contractual clauses approved by the European Union) are agreed with each service provider, unless Company can invoke other legal grounds for the transfer of personal data.

Saving and deleting of data

Company saves personal data for the time necessary for achieving the purposes for which the data was collected and processed, including any retention period stipulated under the applicable legislation (e.g. retention of accounting records) and in any case for a maximum of 24 months after the personal data was collected.

Use of cookies and other tracking technologies

In addition to the above-mentioned processing of personal data, cookies and other tracking technologies are stored on your end device during or after your visit to Company.

Cookies are small text files that are sent when visiting our website or property app and stored in the user’s browser. If the corresponding website is called up again, the user’s browser sends the contents of the cookies back and thus enables the user to be identified. Third party technologies such as scripts, pixels and tags, which Company integrates for advertising purposes, also set cookies on your end device.

Certain cookies are automatically deleted at the end of the browser session (so-called session cookies), others are stored in the user’s browser for a specified time or permanently and then delete themselves automatically (so-called temporary or permanent cookies).

Which cookies does Company use in general?

Depending on their function and purpose, cookies are divided into various categories by Company. “Essential” and “functional” cookies are required to enable Company to provide the online offering in a secure and user-friendly manner. This category includes, for example, cookies that serve to identify or authenticate our users and cookies that temporarily store certain user entries. These cookies enable you to navigate through the Company online offers and use the functions as desired. Without these cookies, essential services of Company cannot be provided. They are only used when you visit our online offers and are usually deleted after closing your browser. They are also used to retrieve the optimized website display when accessed with a mobile device, so that your data volume is not unnecessarily depleted. The legal basis for setting these cookies is the legitimate interest of Company that the online services can be used securely and easily and that the quality of the online services and content is constantly improved. No consent is required for the use of “essential” and “functional” cookies. They cannot be deactivated.

Company also uses cookies for analytical (“analytical cookies”) and advertising purposes (“advertising” cookies). Company uses the profiles created with the help of these cookies for statistical information on the use of Company online services and to display advertising or offers which are tailored to your interests (“interest-based advertising”). The legal basis for the use of these cookies is your consent.

How can you manage and prevent the use of cookies or delete cookies?

You can use Company without “analytical” cookies, “advertising” cookies and other web tracking mechanisms. You can also deactivate the storage of cookies via your browser settings and delete previously stored cookies in your browser at any time. Please note, however, that this online offer may not function or may only function to a limited extent without cookies. We also recommend that you visit the website of www.YourOnlineChoices.com, where you can obtain information and assistance in connection with web tracking mechanisms.

A central opt-out option for various tools, in particular from US American providers, is also available at the following link: optout.networkadvertising.org.

Links to social media pages

This website contains links to the main social media network sites (e.g. Facebook and Twitter). These are not embedded social media plug-ins, but a link through which no personal data is transmitted to the social media operators.

Rights of data subjects

You have the right to information on the processing of your personal data (for example, the origin of this data, the processing purpose, the modalities of the data processing). Under certain conditions, you are also entitled to object to data processing in the future, to restrict it or to request that the data be deleted. Finally, you can prevent the sending of advertising material or the implementation of market research or commercial communications at any time. In summary, you have a right to – information, – correction, – deletion (or to be forgotten), – limitation of processing, – data portability, – objection to the processing of your personal data, – complaint to the supervisory authorities. Please note that your right to deletion is subject to certain restrictions. For instance, we need not or may not delete any data which we need to retain for a further period under a statutory retention period. Data needed by us for the establishment, exercise or defense of legal claims are also excepted from your right to deletion.

To exercise the above rights and to request information, users may write to the following e-mail address office@fis-vienna.com. Similarly, users may at any time revoke consent to, correct and delete the processing of their data.

Contacts

The responsible authority for processing of data is Company. In the event of questions regarding our data processors, we are happy to make a current list of these available to you.

If you have questions about this data protection declaration or about data protection or you have a complaint regarding the way that we process your data, please contact the data protection officer at Company under the above mentioned e-mail address.