Privacy policy
Official privacy and data-processing documents of T. J. Terv Bt.:
Privacy documents
- Privacy policy – T. J. Terv Bt.
- Privacy notice – online contact
- Privacy notice – property brokerage clients
- Privacy notice – property search and viewing clients
- Privacy notice – clients making an offer
- Legitimate interest assessment – property search clients
- Legitimate interest assessment – civil-law claims
1. Legislation underlying the processing
The processing of data carried out on this website (the "Website") is governed by the following legislation:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, GDPR);
- Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Hungary);
- Act CLV of 1997 on Consumer Protection (Hungary).
2. Definitions
- Data controller(s): the natural or legal person who, through owning, operating, storing, maintaining or programming the Website or third-party elements embedded in it, obtains access to personal data provided by Users. May be the primary data controller (the Website owner) or a third-party data controller (a person carrying out a data-processing task on the Website owner's instruction).
- Browser: the program run by the User on the Device to visit and navigate the Website.
- User: the natural or legal person who visits the Website using a Browser run on their Device. This also includes any professional or other assistant, paid or unpaid, whom the User instructs to configure their Device or Browser; the User remains responsible for the correct configuration even when this is done through such a person.
- Written request: a letter delivered by post or courier, in person or through an authorised representative, an open postcard, a telegram, or an e-mail. An SMS or a message sent through a chat interface does not qualify as a written request.
- Device: the electronic equipment and its accessories used by the User to visit the Website (desktop or mobile device).
- Identified data: data linked to a User that includes the User's (or their minor child's) real name, home or registered address, postal address, e-mail address, an identifier assigned by a public authority, phone number, employer details, online username or password, or signature.
- Unidentified data: data linked to a User that contains none of the above (anonymous data).
- Record: a set of several data items relating to one User.
- Oral request: any request made in person or by telecommunication that does not qualify as a written request.
- Web hosting: the remote hardware and software environment in which the Web hosting provider provides an environment suitable for operating the Website; its geographic location is Budapest, Hungary.
- Web hosting provider: the company that provides Web hosting to the Website owner as its service.
- Website owner: the natural or legal person identified as the Website owner in this notice.
- Website: the interface available at https://rdla.hu/, including its source code and the database storing its variable content.
- Visiting the Website (a Website visit): the activity in which the User arrives at the Website, browses its pages, and then leaves it.
- Webmaster: the company responsible, on the Website owner's instruction, for the integrity and functioning of the Website's code.
3. The data controller
Primary data controller and Website owner:
Name: T. J. TERV Bt. (RDL). Registered office: Kossuth Lajos utca 99, 8315 Gyenesdiás, Hungary. Company registration number: 20 06 037638. Tax number: 21535648-2-20. Represented by: Tamás Riedl, managing director. Phone: +36 20 587 4677. E-mail: info@rdla.hu.
3.1 Third-party data controllers
Web hosting provider. Company name: Websupport Hungary Kft. Address: 1119 Budapest, Fehérvári út 97-99, Hungary. Tax number: 25138205-2-43. E-mail: info@mhosting.hu. Data processed: anonymous data related to browsing, and the data submitted through the contact form, which the mail program running on the hosting forwards by e-mail and stores in protected form outside the public web space for no more than 365 days. The provider's privacy notice (Hungarian language): www.mhosting.hu/adatkezelesi-tajekoztato.
Webmaster. The company responsible for the integrity, functioning and maintenance of the Website's code: Grafcom Media Kft. Registered office: 1024 Budapest, Rómer Flóris utca 4, Hungary. Company registration number: 01-09-911489. Tax number: 14604906-2-41. Represented by: Emil Magdó, managing director.
Contact form processing. The data provided in the form is forwarded by e-mail to the Provider by a mail program running on the website's own hosting (Websupport Hungary Kft.); no third-party form service receives the data. The Provider's mailbox is provided by the Gmail service of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). The provider's privacy notice: policies.google.com/privacy.
Anonymous measurement of User behaviour (Google web analytics service). Name: Google Ireland Limited. Registered office: Gordon House, Barrow Street, Dublin 4, Ireland. Company registration number: 368047. Data processed: anonymous data related to browsing, as listed in detail in Google Ireland Limited's privacy notice. Google Ireland Limited's privacy notice.
4. Processing of data provided through the contact form
Data processed when the contact form is completed: name, e-mail address, phone number, and the text of the message provided by the User.
Data is processed in order to answer enquiries, send property offers and prepare a contract. The legal basis is the User's consent, or steps taken at the User's request prior to entering into a contract. The data provided in the form is forwarded by e-mail to the Provider by a mail program running on the website's own hosting, which also sends an automatic confirmation to the e-mail address provided (see section 3.1). The text of the message is stored on the hosting, outside the public web space and password-protected, for no more than 365 days so that it is not lost in the event of an e-mail delivery error. To filter out spam, a hidden check field, a minimum completion time and a sending rate limit are used; for this purpose the sender's IP address is processed for no more than 10 minutes.
Data is kept for 2 years from first contact; where a contract is concluded, for the statutory retention period. Detailed information on data processing connected with a property brokerage instruction is available in the official documents referenced above (the notices prepared for property search and offer-making clients).
5. Data used through the use of the Website and the purposes of processing
5.1 Anonymous data collected for statistical purposes in connection with browsing
The data is controlled jointly by Google Ireland Limited (Ireland) and the Website owner. The data originates from records generated by the User's visit to the Website.
Scope of data: the public IP address of the Device used for browsing; the Browser's user-agent identifier (indicating the type of Device, its operating system, and the Browser's type and version); the User's browsing activity on the Website from arrival until leaving or closing it; the categorisation of the Device (desktop or mobile); and the system log of User activity carried out on the Website.
Purpose of use: anonymous, numerical analysis of the number of Users, of the categories of Devices they use, of Users' geographic location, of visits to individual sub-pages of the Website, and of overall traffic to the Website.
Retention is governed by Google Ireland Limited's prevailing service terms; detailed information is available in Google Ireland Limited's privacy notice.
5.2 Cookies
Cookies are small information files placed among the temporary files of the User's Browser while using the Website, storing settings specified by the User.
Cookies are used, first, to make the User's later browsing easier – if the User blocks the placing of cookies, the browsing-related conveniences they provide will not be available on later visits – and second, to collect anonymous data for the Website owner about Users' browsing habits and the number of visitors to the Website. If the User blocks cookies used to track browsing habits, they may continue browsing the Website without interruption, and the Website owner may not place the User at any disadvantage as a result.
The Website's own code does not place cookies on the User's computer directly. Cookies placed by the Google web-analytics code installed on the Website are governed by Google Ireland Limited's data-processing policy.
6. Access to data and data-security measures
6.1 Access to and transfer of data
Your personal data may be accessed by the data controller's staff for the performance of their duties. The data controller transfers the personal data it processes to the third parties listed in section 3.1 of this notice, for the purposes of maintaining the Website, ensuring its operational security, and operating the web server, under individual agreements or publicly available general terms and conditions. The data controller discloses personal data to organisations not listed in section 3.1 only in exceptional cases required by law – for example, in court proceedings or at the request of an investigating authority.
6.2 Data-security measures
The Website owner may store the User's personal data on the Web hosting, on its own storage media not accessible to others, or on the restricted-access systems of the third-party data controllers listed in section 3.1. The data controller and the third-party data controllers acting on its behalf take appropriate measures to ensure that personal data cannot be accessed or altered by unauthorised persons, and that in the event of a technical fault or malfunction the data can be restored to its original state, or as close to it as possible.
7. The User's rights regarding data processing
7.1 Right of access and information
The User has the right to request confirmation as to whether the data controller processes their personal data and, if so, to receive information about the scope, legal basis, purpose, source and duration of the processing. This right covers identified personal data and pseudonymised data clearly linked to the User; it does not cover unidentified data or the data of other Users.
7.2 Right to rectification
The User has the right to request rectification of their own identified personal data. The data controller corrects or supplements the data upon the User's written request.
7.3 Right to erasure
By written request, the User may ask for their personal data to be erased, in particular where the data is no longer needed for the purpose for which it was collected, where the User withdraws consent and no other legal basis applies, where the User objects to the processing and there is no overriding legitimate ground, or where the processing is unlawful.
7.4 Right to restriction of processing
The User may request restriction of the processing of their data by written request – for example, while contesting the accuracy of the data, where the processing is claimed to be unlawful, or for the establishment, exercise or defence of legal claims.
7.5 Right to data portability
The User has the right to receive the personal data concerning them that they provided to the data controller in a structured, commonly used, machine-readable format, and, based on their consent, to have it transmitted to another data controller they designate, where the processing is carried out by automated means.
7.6 How rights may be exercised
Exercising rights in a non-explicit form means configuring the Browser or Device so as to prevent the collection or transfer of data – in this case the User is not obliged to notify the Website owner. Exercising rights in an explicit form means submitting a written request to the data controller or the Website owner, or, where an online interface is available for this purpose, completing the consent statement provided there. If the User withholds consent, they forgo the services that require the collection of the relevant data; beyond this, the Website owner and the data controllers may not place the User at a disadvantage on account of a non-explicit exercise of rights.
7.7 Form and handling deadline for requests
The data controllers respond to written requests concerning the rights set out in sections 7.1–7.5 of this notice without undue delay, and in any event within 1 month. The request must include the User's name, at least two further items of data enabling identification, and a clear statement of the request. For security reasons, the data controllers do not accept oral requests.
7.8 Right to lodge a complaint
If the User believes their rights have been infringed, they are advised to first seek to resolve the matter directly with the data controllers. If this does not lead to a resolution, the User may turn to the court competent for their place of residence, or to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH). NAIH contact details: 1125 Budapest, Szilágyi Erzsébet fasor 22/c, Hungary; phone: +36 1 391 1400; e-mail: ugyfelszolgalat@naih.hu; website: naih.hu.
8. Amendments to this notice
The data controllers reserve the right to amend this notice at any time. Users will be informed of any amendments by the data controllers – where applicable by e-mail, and in all cases in accordance with the relevant legislation.