This English translation is provided for convenience; in case of any discrepancy, the Hungarian version prevails.

Privacy Notice

On the processing of personal data in connection with the prideandproperty.eu website and prospective HillGate investors · Effective from 1 October 2026

This notice explains which personal data we process when you request an investment pack on our website or otherwise contact us in connection with the HillGate project in Nemesbük, the purposes for which we use such data, how long we retain it and what rights you have. This notice has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, “GDPR”) and Hungarian Act CXII of 2011 on the Right to Informational Self-Determination and on Freedom of Information (“Infotv.”).

1. The controller

Name: PrideAndProperty Építő Kft.
Registered office: 1111 Budapest, Irinyi József utca 31. 1. em. 8., Hungary
Company registration number: 01-09-397140 (Company Registry Court of the Budapest-Capital Regional Court)
Tax number: 27766507-2-43
Email: info@prideandproperty.eu
Telephone: +36 70 390 7728

We are not required to appoint a data protection officer. For any data protection matter, you may contact us at the email address and telephone number above.

2. Which data do we process, for what purposes and on what legal basis?

Processing activity	Data processed	Purpose	Legal basis	Retention period
Request for an investment pack on the website	Name, email address, telephone number (optional), country, investment budget, intended time of purchase, main objective	Sending the investment pack, contacting you, and presenting the apartments and purchase structures suited to you	Your consent, Article 6(1)(a) GDPR	Until consent is withdrawn, but no longer than 2 years from the last contact
Communication by email and telephone	Name, contact details, the content of correspondence and discussions	Answering your questions, arranging matters with you	Consent, Article 6(1)(a) GDPR; in the case of steps prior to entering into a contract, Article 6(1)(b)	For 2 years after the matter is closed; where a contract is concluded, as set out below
On-site viewing, unit reservation, preparation of the contract	Name, contact details, the selected unit, the date of the viewing, and the data required for the reservation and the preparation of the contract	Taking steps prior to entering into a contract, administering the reservation	Steps prior to entering into a contract, Article 6(1)(b) GDPR	Where no contract is concluded, 1 year from the last discussion; where a contract is concluded, until the end of the civil-law limitation period (5 years)
Accounting records	Data contained in invoices and in the contract	Compliance with accounting and tax obligations	Legal obligation, Article 6(1)(c) GDPR; Section 169 of Hungarian Act C of 2000 on Accounting	8 years

The provision of data is voluntary. However, without your name and email address we are unable to send you the investment pack. Please provide only your own data; if you provide data on behalf of another person, it is your responsibility to ensure that the data subject has consented to this.

We do not carry out automated decision-making or profiling. The investment budget and timing provided in the form are used solely to present units relevant to you.

3. Who has access to the data?

The data may be accessed only by those employees of PrideAndProperty Építő Kft. who are responsible for sales and client relations. We do not sell the data to third parties or disclose it to them for marketing purposes.

For our operations we engage the following categories of processors, who may process the data only on our instructions:

Hosting provider: Vital-Comp Ügyvitelszervező és Kereskedelmi Kft. (1037 Budapest, Laborc köz 9., Hungary), operation of the website and the form.
Google Ireland Ltd. (Google Analytics, Google Tag Manager, Google Search Console): audience measurement and management of tracking tags, solely with your consent.
Meta Platforms Ireland Ltd. (Meta Pixel): measurement and targeting of our advertisements, solely with your consent.
Customer relationship management (CRM) and email service provider: recording of enquiries and correspondence.
Legal representative: in the case of a reservation and sale and purchase, the lawyer who prepares the contract.

Where a service provider processes data outside the European Economic Area, we permit this only on the basis of an adequacy decision (for example, the EU–US Data Privacy Framework) or standard contractual clauses adopted by the European Commission.

4. Cookies and measurement tools

On your first visit, we ask you at the bottom of the website which cookies you permit. Until you make a choice, or if you accept only necessary cookies, we do not place any statistics or marketing cookies. You may change your choice at any time using the “Cookie settings” button at the bottom of the page.

Category	Service	Purpose	Legal basis	Lifetime
Necessary	pp_consent (the browser’s local storage)	Remembering your cookie choice	Legitimate interest, Article 6(1)(f) GDPR; exemption under Section 155(4) of Hungarian Act C of 2003 on Electronic Communications (“Eht.”)	Until you delete it
Statistics	Google Analytics 4 (_ga, _ga_*)	Measuring site traffic and the use of content and of the form, in aggregated form	Consent, Article 6(1)(a) GDPR	Up to 2 years
Marketing	Meta Pixel (_fbp), Google advertising measurement	Measuring the performance of our advertisements, targeted advertising on Meta and Google platforms	Consent, Article 6(1)(a) GDPR	Up to 90 days (_fbp); up to 2 years for Google cookies

The tracking tags are loaded by Google Tag Manager, which does not itself place any cookies and, in line with Google’s Consent Mode, activates only the categories you have permitted. We do not pass the name, email address and telephone number you provide in the form to the measurement tools.

Google and Meta may also transfer data to the United States; such transfers are based on the EU–US Data Privacy Framework, to which both companies have self-certified. Fonts are loaded from the Google Fonts service, in the course of which your browser transmits your IP address to Google.

5. How do we protect the data?

Access to the data is limited to those who need it for their work. The website transmits form data over an encrypted (HTTPS) connection. We select our processors so that they protect the data by appropriate technical and organisational measures.

6. Your rights

Right of access: you may request information on which of your data we process and request a copy of such data (Article 15 GDPR).
Right to rectification: you may request the correction of inaccurate data (Article 16).
Right to erasure: you may request the erasure of your data where it is no longer necessary for the purposes of processing or where you have withdrawn your consent (Article 17).
Right to restriction of processing: you may request that, for a specified period, we only store your data (Article 18).
Right to data portability: you may request that we provide your data in a machine-readable format (Article 20).
Right to object: you may object to the processing of your data (Article 21).
Withdrawal of consent: at any time, without giving reasons, by a single email. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal (Article 7(3)).

You may send your request to info@prideandproperty.eu. We will respond within one month at the latest; where justified, this period may be extended by two further months, in which case we will inform you accordingly.

7. Remedies

If you consider that the processing of your data infringes the law, please contact us first so that we can remedy the issue. You may also lodge a complaint with the supervisory authority:

Authority: Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Address: 1055 Budapest, Falk Miksa utca 9–11., Hungary
Postal address: 1363 Budapest, Pf. 9., Hungary
Telephone: +36 1 391 1400
Email: ugyfelszolgalat@naih.hu
Website: www.naih.hu

You may also bring legal proceedings before the courts if your rights are infringed. At your choice, proceedings may also be brought before the regional court having jurisdiction over your place of residence or place of stay.

8. Amendments to this notice

If the manner of processing changes (for example, if we engage a new service provider or introduce a new measurement tool), we will update this notice and publish the change on the website.

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