Privacy Policy
Effective: 2026. július 20.
Somogyi Öthalom Kft. (the "Controller") is committed to protecting personal data. This policy has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and Hungarian Act CXII of 2011 on informational self-determination and freedom of information.
1. The controller
Somogyi Öthalom Kft. is responsible for the processing of your personal data. The Controller's full identification and contact details are set out on the Legal Notice page.
The Controller has not appointed a data protection officer, as its activities do not fall within the cases listed in Article 37(1) GDPR. For any data protection matter, please contact the Controller directly using the details above.
2. What data do we process?
Personal data is collected on this website only when you complete the contact form. The form may collect:
- Name — required, for addressing and identifying you
- Email address — required, so that we can reply
- Phone number — optional, if you would like a call back
- Subject of your enquiry (selected apartment or parking space) — optional
- Message text — required
As part of the technical operation of the form, our service provider logs the time of submission and the sender's IP address in order to filter abusive use (spam).
Please include only the data necessary for your enquiry. Do not share special category data (health data, religious or political beliefs, etc.) with us.
3. Purpose and legal basis of processing
Purpose of processing: responding to your enquiry, providing information about the properties, and preparing a potential sale and purchase agreement.
- The legal basis for processing the data you submit through the form is your voluntary consent — Article 6(1)(a) GDPR. You give consent by ticking the checkbox before submitting the form.
- If your enquiry leads to preparation of a contract, the legal basis is the taking of steps at your request prior to entering into a contract — Article 6(1)(b) GDPR.
- The legal basis for technical logging used to filter abuse is the legitimate interest of the Controller and its service provider in maintaining the security of the system — Article 6(1)(f) GDPR.
Providing your data is not a statutory obligation. However, it is a condition of contacting us through the form — without it we cannot reply to you.
4. How long do we keep your data?
- If the enquiry does not lead to a contract: for 2 years from the last contact, or until you withdraw your consent — whichever occurs first.
- If a sale and purchase agreement is concluded: data relating to the contractual relationship is retained for 8 years pursuant to Section 169 of Hungarian Act C of 2000 on accounting, and certain data for 5 years from termination of the contract in view of the civil law limitation period.
- Technical log data is stored by our service provider for a maximum of 30 days.
Once the retention period expires, the data is permanently and irreversibly deleted.
5. Who has access to your data?
Access is limited to the Controller's sales staff, to the extent necessary to perform their duties. We do not sell your data and do not transfer it to third parties for marketing purposes.
Viewings and enquiry handling are carried out by Zoltán Őri, an estate agent acting on behalf of the Controller, within Dr. Hernádi Ügyvédi Iroda (law office; registered seat: 6800 Hódmezővásárhely, Hősök tere 1. fsz. 2.; registered by the Szeged Bar Association; tax number: 18740316-2-06; represented by Dr. Gyula Hernádi, attorney, bar ID [KASZ]: 36061479). The appointed estate agent therefore also receives the data you submit through the form, solely for the purpose of answering your enquiry and showing the property. The data may not be used for their own purposes and is subject to confidentiality under the agency and data processing agreements concluded with the Controller.
The website is operated by VRG IT Solutions Kft. (registered seat: 2073 Tök, Fő utca 1.; tax number: 27400221-2-13) as a data processor on behalf of the Controller. Messages submitted through the contact form are delivered to the project's dedicated shared mailbox (info@hodikotapartments.hu), hosted by DotRoll Kft. (1148 Budapest, Fogarasi út 3-5.) with data stored within the EU. This mailbox is accessed by the website operator (VRG IT Solutions Kft.) and the appointed estate agent, solely to answer your enquiry and show the property. They open the mailbox using Google's (Gmail) email service, so the messages are also processed within Google's systems. Everyone involved is bound by confidentiality and does not use the data for their own purposes.
We use the following technical service providers as processors:
Among the providers above, Web3Forms, Netlify and Google may also process data in the United States (DotRoll stores data within the European Union). Transfers to third countries are covered by the standard contractual clauses (SCC) adopted by the European Commission and/or certification under the EU–U.S. Data Privacy Framework. You may request further information about these safeguards from the Controller.
6. Cookies and analytics
This website does not use tracking, profiling or marketing cookies, and does not run any third-party analytics service (such as Google Analytics or Meta Pixel).
Apart from cookies strictly necessary for the operation of the website, we do not store any data on your device, which is why no cookie consent banner is displayed.
The About page embeds an OpenStreetMap map. When the map loads, your IP address is transmitted to the servers of the OpenStreetMap Foundation. You can read about their processing at osmfoundation.org/wiki/Privacy_Policy.
7. Your rights
Under the GDPR you have the following rights in relation to the processing of your personal data:
- Right of access — you may ask whether we process data about you and, if so, request a copy of it.
- Right to rectification — you may request correction of inaccurate data or completion of incomplete data.
- Right to erasure ("right to be forgotten") — you may request deletion of your data if the purpose of processing has ceased or you withdraw your consent.
- Right to restriction of processing — you may request suspension of processing, for example while you contest the accuracy of the data.
- Right to data portability — you may request your data in a structured, machine-readable format, or ask us to transmit it to another controller.
- Right to object — you may object to processing based on legitimate interest.
- Right to withdraw consent — you may withdraw your consent at any time without giving reasons. Withdrawal does not affect the lawfulness of processing carried out before it.
Please send your request to the email address or registered seat given in the Legal Notice. We will respond within 1 month at the latest; in justified cases this may be extended by a further 2 months, of which we will inform you. The procedure is free of charge.
8. Remedies
If you believe your data has been processed unlawfully, please contact us first — most issues can be resolved quickly.
You may also lodge a complaint with the supervisory authority:
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Falk Miksa utca 9–11, 1055 Budapest, Hungary
Postal address: 1363 Budapest, Pf. 9.
+36 1 391 1400 · ugyfelszolgalat@naih.hu
www.naih.huYou may also bring court proceedings. At your choice, the action may be brought before the regional court of your place of residence or stay.
9. Data security
The website is served over an encrypted HTTPS connection, so data submitted through the form is protected in transit. Access is limited to authorised staff bound by confidentiality obligations.
The Controller applies technical and organisational measures appropriate to the level of risk to protect data against accidental or unlawful destruction, loss, alteration and unauthorised disclosure.
10. Changes to this policy
The Controller reserves the right to amend this policy. The version in force at any time is available on this page, with the effective date shown at the top. In the event of a material change we will inform data subjects by appropriate means.