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DATA PROCESSING POLICY for business partners

Introduction

108 HUNGARY REAL ESTATE Limited Liability Company (hereinafter: the Company or 108 HUNGARY REAL ESTATE Ltd.) handles the personal data of its business partners — that is, the data required for establishing contact prior to business activities, for the exchange of necessary supplementary information during business activities, and for fulfilling contracts—as follows: 108 HUNGARY REAL ESTATE Ltd. is committed to protecting the personal data of its partners and considers the respect of their informational self-determination rights important. Therefore, it handles personal data confidentially and implements the necessary security, technical, and organizational measures to guarantee the security of the data.

Contractual Basis

Contracts or agreements between 108 HUNGARY REAL ESTATE Ltd. and a given contracting party may include the name and contact details of the contracting individual and contact persons involved in the matter, as well as possibly other data. 108 HUNGARY REAL ESTATE Ltd. processes the data of the contracting party (business partner) on the legal basis defined in Article 6(1)(b) of the GDPR—i.e., for the performance of a contract—and solely for the purpose of fulfilling the given contract or agreement. Maintaining communication between the parties is essential for the fulfillment of the contract.

Data Controller

The legal entity that determines the purposes and means of processing personal data, either independently or jointly with others. In this context, 108 HUNGARY REAL ESTATE Ltd. qualifies as the data controller. Contact of the data controller: 108 HUNGARY REAL ESTATE Ltd. Seat: 1122 Budapest, Ráth György utca 56. Company registration number: 01-09-356375 Ta108 HUNGARY REAL ESTATE number: 27907003 -2-43

Data Processing Details

Purpose of data processing: To fulfill a contract or agreement Legal basis of data processing: Article 6(1)(b) of the GDPR (2016/679 EU Regulation) Scope of data processed: - For contracting individuals: name, address, possibly license number, place and date of birth - For contact persons listed in the contract: name, title, position, email address, phone number Data retention period: Until the fulfillment of the given contract or agreement, or as long as required by law; data will be deleted afterward. Persons authorized to access the data: Executives of 108 HUNGARY REAL ESTATE Ltd., contact persons handling the matter, and contracted advisors (processors under contract with the controller, e.g., lawyers, auditors) Data transfer: No data will be transferred to third parties, except in cases of official or court orders. In such cases, 108 HUNGARY REAL ESTATE Ltd. will only release data to the extent absolutely necessary to fulfill the request, with the legal basis being the authority’s or court’s final ruling and compliance with legal obligations under the GDPR. Consequences of failing to provide data: Failure to establish or fulfill a contract or agreement.

Data Security

108 HUNGARY REAL ESTATE Ltd. takes appropriate technical and organizational measures to protect personal data. This includes: - Controlled access to IT systems based on necessity - Use of hardware firewalls at all public network entry points - Redundant data storage to prevent loss - Antivirus and malware protection - Secure VPN access for external connections - Logging and monitoring systems to detect unauthorized access All processors and the controller commit to strict confidentiality rules in writing.

Rights of the Data Subjects

Data subjects have the right to: - Access their personal data and related information - Rectify inaccurate or incomplete data - Delete their personal data - Restrict the processing of their data temporarily or permanently - Data portability - Object to decisions based solely on automated processing The controller shall respond to requests without undue delay and within legal time limits. If the request is submitted electronically, the response should also be electronic unless otherwise requested. If no action is taken, the controller must inform the subject of the reasons and legal remedies.

Legal Remedies

Complaints may be submitted to the National Authority for Data Protection and Freedom of Information: Name: Nemzeti Adatvédelmi és Információszabadság Hatóság Address: 1055 Budapest, Falk Miksa utca 9-11. Mailing address: 1363 Budapest, Pf. 9. Phone: +36 1 391 1400 Fa108 HUNGARY REAL ESTATE: +36 1 391 1410 Email: ugyfelszolgalat@naih.hu Website: http://www.naih.hu Court Action: Legal action may be taken at the competent court of the data subject’s residence or place of stay. (Details at http://birosag.hu). It is recommended to first send complaints to the data controller.

Legal Basis

This notice has been prepared in accordance with the following legal regulations: - GDPR (Regulation (EU) 2016/679) - Act C108 HUNGARY REAL ESTATEII of 2011 on Information Self-Determination and Freedom of Information - Civil Code (Act V of 2013) - Code of Civil Procedure (Act C108 HUNGARY REAL ESTATE108 HUNGARY REAL ESTATE108 HUNGARY REAL ESTATE of 2016) - Accounting Act (Act C of 2000)

DATA PROCESSING POLICY

Introduction

108 HUNGARY REAL ESTATE Limited Liability Company (hereinafter: the Company or 108 HUNGARY REAL ESTATE Ltd.) handles the personal data of its business partners — that is, the data required for establishing contact prior to business activities, for the exchange of necessary supplementary information during business activities, and for fulfilling contracts—as follows: 108 HUNGARY REAL ESTATE Ltd. is committed to protecting the personal data of its partners and considers the respect of their informational self-determination rights important. Therefore, it handles personal data confidentially and implements the necessary security, technical, and organizational measures to guarantee the security of the data.

Contractual Basis

Contracts or agreements between 108 HUNGARY REAL ESTATE Ltd. and a given contracting party may include the name and contact details of the contracting individual and contact persons involved in the matter, as well as possibly other data. 108 HUNGARY REAL ESTATE Ltd. processes the data of the contracting party (business partner) on the legal basis defined in Article 6(1)(b) of the GDPR—i.e., for the performance of a contract—and solely for the purpose of fulfilling the given contract or agreement. Maintaining communication between the parties is essential for the fulfillment of the contract.

Data Controller

The legal entity that determines the purposes and means of processing personal data, either independently or jointly with others. In this context, 108 HUNGARY REAL ESTATE Ltd. qualifies as the data controller. Contact of the data controller: 108 HUNGARY REAL ESTATE Ltd. Seat: 1122 Budapest, Ráth György utca 56. Company registration number: 01-09-356375 Ta108 HUNGARY REAL ESTATE number: 27907003 -2-43

Data Processing Details

Purpose of data processing: To fulfill a contract or agreement Legal basis of data processing: Article 6(1)(b) of the GDPR (2016/679 EU Regulation) Scope of data processed: - For contracting individuals: name, address, possibly license number, place and date of birth - For contact persons listed in the contract: name, title, position, email address, phone number Data retention period: Until the fulfillment of the given contract or agreement, or as long as required by law; data will be deleted afterward. Persons authorized to access the data: Executives of 108 HUNGARY REAL ESTATE Ltd., contact persons handling the matter, and contracted advisors (processors under contract with the controller, e.g., lawyers, auditors) Data transfer: No data will be transferred to third parties, except in cases of official or court orders. In such cases, 108 HUNGARY REAL ESTATE Ltd. will only release data to the extent absolutely necessary to fulfill the request, with the legal basis being the authority’s or court’s final ruling and compliance with legal obligations under the GDPR. Consequences of failing to provide data: Failure to establish or fulfill a contract or agreement.

Data Security

108 HUNGARY REAL ESTATE Ltd. takes appropriate technical and organizational measures to protect personal data. This includes: - Controlled access to IT systems based on necessity - Use of hardware firewalls at all public network entry points - Redundant data storage to prevent loss - Antivirus and malware protection - Secure VPN access for external connections - Logging and monitoring systems to detect unauthorized access All processors and the controller commit to strict confidentiality rules in writing.

Rights of the Data Subjects

Data subjects have the right to: - Access their personal data and related information - Rectify inaccurate or incomplete data - Delete their personal data - Restrict the processing of their data temporarily or permanently - Data portability - Object to decisions based solely on automated processing The controller shall respond to requests without undue delay and within legal time limits. If the request is submitted electronically, the response should also be electronic unless otherwise requested. If no action is taken, the controller must inform the subject of the reasons and legal remedies.

Legal Remedies

Complaints may be submitted to the National Authority for Data Protection and Freedom of Information: Name: Nemzeti Adatvédelmi és Információszabadság Hatóság Address: 1055 Budapest, Falk Miksa utca 9-11. Mailing address: 1363 Budapest, Pf. 9. Phone: +36 1 391 1400 Fa108 HUNGARY REAL ESTATE: +36 1 391 1410 Email: ugyfelszolgalat@naih.hu Website: http://www.naih.hu Court Action: Legal action may be taken at the competent court of the data subject’s residence or place of stay. (Details at http://birosag.hu). It is recommended to first send complaints to the data controller.

Legal Basis

This notice has been prepared in accordance with the following legal regulations: - GDPR (Regulation (EU) 2016/679) - Act C108 HUNGARY REAL ESTATEII of 2011 on Information Self-Determination and Freedom of Information - Civil Code (Act V of 2013) - Code of Civil Procedure (Act C108 HUNGARY REAL ESTATE108 HUNGARY REAL ESTATE108 HUNGARY REAL ESTATE of 2016) - Accounting Act (Act C of 2000)

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