Privacy policy of VÖLGY 32 Ingatlankezelő és Tanácsadó Kft. (hereinafter "Völgy 32", "we", "operator" or "data controller"), effective from 4 May 2026 (hereinafter "Policy", "Notice" or "Guideline").

Introduction

This privacy policy describes the protection of the data of persons visiting our website ("website") and using our services ("services"). Your privacy is important to us. Our goal is to provide a personalised online experience that delivers the most relevant and useful information, data sources and services to you. This policy describes the conditions under which the website and our services are made available to you. It explains how we collect and use the data obtained during your visit and use of this website. We recommend that you read this notice carefully.

By using the website you agree to accept the privacy policy set out here. If you do not agree, we suggest that you stop accessing the website or any materials available from it. If you are dissatisfied with our website, please contact us. The website is provided as a public service.

The development of the content and operation of the website is an ongoing process. The operator may decide to change the terms of this policy in the future without prior notice — for example to improve user experience or to maintain legal compliance. Use of the website at any given time constitutes your consent to the privacy notice in force at that time. The current policy is published on this website.

Scope of this notice

This privacy policy applies to volgy32.hu, including any sub-domains.

Our website may contain links to other websites; the data practices and content of those sites are governed by their own privacy notices. We recommend that you review them.

Data controllers and processors

A data controller is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

A data processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

For most personal data we handle we are both controllers and processors; in some cases we act only as processors. A separate list of processors and controllers is included at the end of this policy.

Information you provide

We may request and collect personal data about you, such as your name, address, telephone number, e-mail address and certain related information (such as your company name and tax number) when you submit a rental enquiry or otherwise contact us. By voluntarily providing this information, you confirm that you own this personal data or that you otherwise have the authority required to share it with us.

Types of information collected

Personal data

In this Policy, personal data means any information relating to an identified or identifiable natural person (data subject). The use of information collected through the website is limited to providing the website. We use personal data to better understand your needs and interests and to better serve you. When submitting a rental enquiry you may provide a name, address, telephone number, e-mail address and company information. We do not store credit-card data.

Non-personal data

Non-personal data is data and information arising from usage operations that is not directly linked to a specific identity. The operator may collect and analyse non-personal data to evaluate how visitors use the operator's website.

Aggregated information

The operator may collect aggregated statistics — information automatically provided by your computer that cannot be linked to your individual identity. Examples include referrer data (the address of the website visited immediately before this one), the list of pages requested and viewed on this website, the time spent on the website, and your IP address.

Cookies and technical storage (localStorage)

This website does not set HTTP cookies. The browser's localStorage is used solely for two strictly functional purposes:

To remember your chosen appearance (light / dark theme).
To remember that you have acknowledged our notice on cookies and technical storage, so that the notice does not reappear on every page load.

These entries do not contain personal data, are not shared with third parties, and qualify as "strictly necessary" storage under the EU ePrivacy Directive — they therefore do not require prior consent. Stored data can be erased at any time using your browser's data-clearing function.

This website does not use web beacons or pixel trackers. For visitor statistics we use Google Analytics 4 (GA4) — but it loads only with your explicit consent. You can give consent by clicking "Accept" in the cookie notice at the bottom of the website, or refuse it by clicking "Reject". Consent can be withdrawn at any time: clearing the browser's site data (localStorage) makes the notice reappear and lets you decide again. Cookies set by GA4 (e.g. _ga, ga*) only appear in your browser after consent.

Third-party processors and embedded services

We may use the following third-party providers to operate and render the website:

Cloudflare, Inc. (San Francisco, USA) — content delivery network (CDN) and edge cache. In this role, Cloudflare processes visitor IP addresses and request metadata (e.g. User-Agent, URL) on our behalf, under Cloudflare's Data Processing Addendum (DPA) and Standard Contractual Clauses (SCC).
OpenStreetMap Foundation (United Kingdom) — the map tiles on the Contact page are loaded directly from OpenStreetMap servers by your browser. Your IP address is then visible to OSM servers for the purpose of delivering the tiles. OpenStreetMap's privacy policy is available at wiki.osmfoundation.org/wiki/Privacy_Policy.
Google Ireland Limited / Google LLC — Google Analytics 4 (GA4), a web statistics service that loads only with your explicit consent. If you accept, your browser communicates with the googletagmanager.com and google-analytics.com domains; Google then processes your IP address (in shortened/anonymised form within the EU), the URLs visited, browser and device characteristics, and interaction events. GA4 processing is carried out under the EU-US Data Privacy Framework (TADPF) and Google's Standard Contractual Clauses (SCC). Advertising personalisation and Google Signals features are disabled. Consent can be withdrawn at any time, after which GA4 will no longer load; previously placed cookies can be removed via your browser's data-clearing function.

The website does not call any other third-party service (no Google Fonts, no social-media embeds, no advertising network). The fonts (Titillium Web) are served from our own server.

How we use your information

The operator may use non-personal data to produce and present aggregated reports on the use, performance and effectiveness of the website, or to improve the website's usability and content.

The operator may use personal data to provide services that support enquiries, quote requests and lease negotiations. The operator may share your personal data with partners for the establishment or facilitation of transactions or for legal compliance.

Retention

We retain your personal data for as long as you use the service and remain subscribed, or as long as a legal obligation requires. Some data is retained beyond the end of the service in accordance with statutory requirements.

Information related to invoices is retained for 8 years.
Complaint records are retained for 5 years.

Information sharing

The operator does not sell, rent or lease individuals' personal data or e-mail address lists for marketing purposes, and takes commercially reasonable steps, in compliance with statutory requirements, to keep this information secure. The operator reserves the right to transfer all such information to any organisation into which the operator may merge or be acquired in the future, in order for that third party to continue these activities. We reserve the right to disclose personal data in defence of our system or business if we reasonably believe that you have breached our terms of use, or that you have initiated or participated in illegal activity. In certain circumstances the operator is obliged to disclose personal data under court or other official order.

Given that the website has international reach, personal data may be visible to persons outside your country of residence.

Your rights and remedies

You may exercise your rights regarding our processing by sending a request to volgy32@entel.hu, or in writing — for example by registered or signed-for letter to the controller's postal address. The controller is required to respond within 30 days of receipt. Your rights may be limited in special cases by applicable law. Your rights are:

Access: under Article 15 of EU Regulation 2016/679, on request we will inform you of the scope of personal data we process about you, and of the purposes, legal basis, retention and other relevant aspects of the processing.
Rectification: you have the right to have inaccurate personal data corrected without undue delay.
Erasure: you have the right to have personal data about you erased without undue delay, except where the law requires retention.
Restriction: you have the right to request restriction of processing. This typically applies where erasure would harm your interests.
Portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another controller, or have us transmit it.
Objection: you may object to the processing of your personal data — including profiling and direct marketing — where the processing is not based on a legal obligation.

If you have any comments, complaints or correction requests regarding the content of our website, please contact us — we will respond within 30 days.

If we breach or fail to fulfil your rights regarding personal data, you may seek judicial remedy. Damages caused by your own negligent conduct may not be claimed.

In case of a breach of your right to informational self-determination, you may file a report or complaint with:

National Authority for Data Protection and Freedom of Information (NAIH) Address: H-1055 Budapest, Falk Miksa utca 9-11., Hungary Postal address: H-1363 Budapest, Pf. 9. Phone: +36 (1) 391-1400 — Fax: +36 (1) 391-1410 https://www.naih.hu ugyfelszolgalat@naih.hu

For complaints regarding content harmful to minors, hate speech, exclusion, rectification, the rights of deceased persons or defamation, you may contact:

National Media and Infocommunications Authority (NMHH) H-1015 Budapest, Ostrom u. 23-25. Postal address: H-1525 Budapest, Pf. 75 Tel: +36 (1) 457 7100 — Fax: +36 (1) 356 5520 http://www.nmhh.hu info@nmhh.hu

Access to information and accuracy

We are committed to keeping personal data about you up-to-date and accurate. All information provided to us can be reviewed and modified by you. Please send change requests to volgy32@entel.hu.

Security

The operator takes all reasonable measures to protect personal data, including firewall and other security measures on its servers. However, no server can guarantee complete security, and you should take this into account when providing personal or confidential information to any website, including this one. The operator is not liable for the protection of information you provide against interception, alteration or misuse. You alone are responsible for the confidentiality of your personal data. Please use the website with discretion and provide personal data with discretion.

In the event of a personal data breach we act in accordance with Article 33 of EU Regulation 2016/679.

Processing of children's data

The operator is committed to protecting the privacy of children and encourages parents and guardians to take an active role in their children's online activity and interests. The operator does not knowingly collect data about minors and does not specifically target this website at children.

List of processors

Entel Kft. — website operation, IT infrastructure, data processing (Hungary)
Cloudflare, Inc. — CDN, edge cache (San Francisco, USA)
OpenStreetMap Foundation — map tiles (United Kingdom)
Google Ireland Limited / Google LLC — Google Analytics 4 (only with consent)