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Privacy Policy

CHAPTER I – General Provisions

1. Introduction

This Privacy Policy provides information on the processing of personal data by [Oritthi Commerciale Kft.] (hereinafter: the “Company”) in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”) and applicable Hungarian law.

This policy details:

  • The scope and manner of personal data processing,

  • The rights of data subjects,

  • The measures implemented to protect personal data.

2. Definitions

For the purposes of this policy:

  • Personal data: any information relating to an identified or identifiable natural person;

  • Data subject: the natural person whose data is processed;

  • Processing: any operation performed on personal data (collection, storage, use, etc.);

  • Controller: the Company that determines the purposes and means of the processing;

  • Processor: a third party processing personal data on behalf of the controller;

  • Recipient: a natural or legal person to whom the data are disclosed;

  • Consent: freely given, specific, informed, and unambiguous indication of the data subject’s wishes.

3. Legal Basis for Processing

Processing is based on:

  • The data subject’s consent,

  • The performance of a contract,

  • Legal obligations applicable to the Company,

  • The legitimate interest of the Company or a third party.

 

CHAPTER II – Identity and Contact Details of the Controller

Name of the Controller: Oritthi Commerciale Kft.
Registered Seat: Hungary, 1027 Budapest, Bem József utca 6. fszt.
Company Registration Number: 0109309758
Tax number: HU26242583
Email: info@euresy.com
Website: euresy.com

CHAPTER III
NAME OF DATA PROCESSORS

In accordance with Article 4(8) of the General Data Protection Regulation (GDPR), a processor refers to a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

While the use of a processor does not require prior consent from the data subject, the data subject must be informed. Therefore, we provide the following details about the data processors we use in relation to the processing of personal data:

1. IT and Cloud Service Providers

Our Company uses the following service providers to assist in the management of its IT systems and services, including email, storage, and system administration, during the period of our contracts with them:

2. Accounting and Financial Service Providers

For the purpose of fulfilling our tax and accounting obligations, we engage the following external service provider, which processes personal data to ensure compliance with applicable laws and regulations:

3. Service providers

For the purpose of fulfilling the needs of the Data subject we are generate leads for the below companies who will provide the chosen services.

 

CHAPTER IV – Processing Data in Relation to the Provision of Services

1. Visiting the Website – Use of Cookies

(1) Use of Cookies

The Company uses cookies to improve the functionality and user experience of its website. Cookies are small data files stored on the user’s device.

(2) Data Processed via Cookies:

  • Visitor’s IP address,

  • Browser type,

  • Language settings of the operating system,

  • Date and time of visit,

  • Visited subpages and functions used.

(3) Cookie Settings

Use of cookies is not mandatory. Users can adjust browser settings to disable cookies. However, some website features may not function correctly if cookies are disabled.

Cookie setting guides for popular browsers:

(4) Cookies Do Not Identify Individuals

Cookies used on the website do not directly identify users.

(5) Types of Cookies Used

i. Strictly Necessary (Session) Cookies

  • Purpose: Ensure proper website functionality.

  • Legal basis: Article 13/A (3) of Act CVIII of 2001.

  • Retention: Until the end of the session.

ii. Consent-Based Cookies

  • ii.1. Functional Cookies

    • Purpose: Improve service performance and user experience.

    • Retention: 6 months.

    • Examples: ZOPIM, ADDTOANY

  • ii.2. Performance Cookies

2. Newsletter Subscription

(1) Consent

Consent is given by ticking the checkbox during registration. Unsubscribing can be done at any time via the “Unsubscribe” link or by contacting the Company.

(2) Data Categories

  • Full name,

  • Email address,

  • Country of residence,

  • Service group of interest.

(3) Purpose

  • Sending newsletters about products and services,

  • Sending promotional content.

(4) Legal Basis

  • Consent of the data subject.

(5) Recipients

  • Company employees responsible for customer service and marketing,

  • IT service provider.

(6) Retention

Until unsubscription or withdrawal of consent.

3. Contact Forms and Email Inquiries

(1) Consent

Consent is given by ticking the relevant checkbox when submitting the form.

(2) Data Processed

  • Name,

  • Phone number,

  • Email address,

  • Nationality,

  • Content of message provided in free text format,

  • Information about the wanted service

    • Type of real estate

    • Service type

    • EU residency status 

(3) Purpose

  • Providing information and quotations,

  • Contacting the requester,

  • Service eligibility assessment.

(4) Legal Basis

  • Consent or necessity for fulfilling the requester’s inquiry.

(5) Recipients

  • Service provider and IT service provider staff.

(6) Retention

6 months or until withdrawal of consent.

CHAPTER V – Processing Based on Legal Obligation

1. Processing Personal Data for Tax and Accounting Compliance

(1) The Company processes personal data of natural persons entering into a business relationship with it (e.g. as clients or suppliers) to meet its legal tax and accounting obligations. This includes name, address, tax number, tax status, and, where applicable, payment and service confirmation details, in accordance with Act CXXVII of 2017 on VAT.

(2) Data is retained for 8 years after the end of the legal relationship.

(3) Access is granted only to employees and contracted service providers responsible for tax, accounting, payroll, and social security.

 

CHAPTER VI – Data Subject Rights (your rights in relation to processing your personal data)

To ensure transparency, this section outlines your rights regarding the processing of your personal data.

  • Right to Information
    You have the right to be informed about the purpose, legal basis, and scope of data processing before it begins.

  • Right of Access
    You may request confirmation of whether your personal data is being processed and access the relevant information.

  • Right to Rectification
    You can request the correction of inaccurate or incomplete personal data without undue delay.

  • Right to Erasure ("Right to Be Forgotten")
    You may request the deletion of your personal data if certain legal grounds apply, as defined by the Regulation.

  • Right to Restrict Processing
    You can request the restriction of data processing under specific conditions set by the Regulation.

  • Notification Obligation
    If your data is corrected, deleted, or restricted, we will notify all recipients, unless doing so is impossible or involves disproportionate effort. You may request a list of these recipients.

  • Right to Data Portability
    Under certain conditions, you can request your data in a structured, machine-readable format and transfer it to another controller.

  • Right to Be Informed About Data Breaches
    If a data breach poses a high risk to your rights and freedoms, we will inform you without undue delay.

  • Right to Lodge a Complaint
    You may file a complaint with a supervisory authority in your country of residence, workplace, or where the alleged breach occurred if you believe your data is being processed unlawfully.

CHAPTER VII – Submitting Requests Related to Data Processing

We will respond to any request regarding your data rights without undue delay, and within one month of receipt. If more time is needed due to complexity or volume, we may extend this by up to two months and will inform you of the reason for the delay within the initial one-month period.

If you submit your request electronically, we will respond in a commonly used electronic format, unless you ask otherwise.

If we are unable to act on your request, you will be informed within one month, including the reason and your right to lodge a complaint with a supervisory authority or seek legal remedy.

Under Articles 13–14 and 15–22, 34 of the GDPR, all information and communication will be provided free of charge. However, if a request is clearly unfounded or excessive, especially if repeated, we may:

  • Charge a fee of HUF 10 000, or

  • Refuse to act on the request.

In such cases, we are responsible for proving that the request was unfounded or excessive.

If we have doubts about your identity, we may request additional information to confirm it.

 

Oritthi Commerciale Kft., 6th of May 2025

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