Data protection policy

1. General legal statement
This data protection policy contains general information regarding data processing and policies relating in particular to the processing of personal data necessary for SP Residence Kft. (as Data Controller) to send general information in electronic mails, in other words, newsletters.

We process the personal data of those persons of age (who are over 18), who have consented voluntarily and in writing to receiving our newsletters.

We would like to inform you that you may withdraw your consent to receiving newsletters at any time. You may do so by clicking on the “Unsubscribe” button displayed on the footer of the newsletter, or by letting us know of your intention to unsubscribe at any of the contacts listed below.

2. Name of the data controller:
Name: SP Residence Ingatlanfejlesztő Korlátolt Felelősségű Társaság
Company registration number: 01-09-303538
TIN: 26131050-2-41
Seat and postal address: 1053 Budapest, Reáltanoda utca 5.
Email address:
Phone number: + 36 (1) 200 2904

3. The legal basis of data processing:
We would like to inform you that we will only send a newsletter once you have given your express written consent.

In accordance with the above, the legal basis of the data processing is consent as stated by Cipher a) Point (1) Section (5) of the Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, as well as Cipher a) Point (1) Section 6 of the 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, and repealing Directive 95/46/EC (General Data Protection Regulation).

4. Purpose of data processing:
The purpose of sending the newsletter is to inform those persons about general information, who have stated an interest in such information.

5. Scope of personal data:
In order to be able to send you a newsletter we request you supply the following information:
your name;
e-mail address

Please, provide real data in all instances.

We shall neither request nor accept data other than the ones requested above, therefore we would like to ask you not to send or give us or share with us any other personal data or sensitive data (for instance, data relating to your health, political or religious belonging).

Collection and processing of personal data will be done exclusively with your express consent and agreement, through voluntary data provision by you.

We will process the processed personal data solely to the extent necessary to send newsletters, to the extent necessary for this purpose.

6. Data processing and forwarding
We, SP Residence Kft will be sending the newsletters, therefore the personal data you share with us if you wish to receive these newsletters will not be known to anyone else.

7. Timeframe of data processing:
We will send you the newsletter until you unsubscribe from our newsletter (or until you withdraw your consent, or you request that we delete your data in accordance with the clauses below).

8. Data storage
We store the personal data provided by you in an electronic way, on servers stored in a server room run by our internet service provider (Creative Management Kft. 8200 Veszprém, Boksa tér 1/A., TIN: 13881676-2-19), the address of which is 1 Rue du Havre, 67100 Strasbourg, France.

9. Your rights and legal remedies
You have numerous rights when your personal data is processed. You may exercise these rights by sending us a request to any of the contact details provided in Point 2.

The right to access and correct your personal data
You always have the right to access, request a copy of, and further to correct or refresh your personal data.

In accordance with the right of access you have the right to receive information about the following:
a) purpose of data processing;
b) categories of the personal data involved;
c) those recipients or categories of recipients whom your personal data has been forwarded to or will be forwarded to, including in particular recipients in third countries or international organizations;
d) in particular cases, the planned timeframe of data storage;
e) the right of the data subject to request from the data controller that his/her personal data be corrected, deleted or their processing restricted, and he/she may object to processing;
f) a right to lodge a complaint with an appropriate supervisory authority.

We appreciate the importance of your rights, therefore, should you wish to exercise them, please contact us at any of the contact details listed in Point 2.

Right to data portability
Your personal data are portable, therefore your have the right to receive a copy of them in a common, broadly used format readable by computers. This means that you will receive a copy of your personal data we processed in a format that can be read by a computer and transferred by you in an electronically to a different person.

Should you wish to exercise your right to data portability, please contact the Data Countroller at any of the contact details listed in Point 2.

Right to personal data deletion
You have the right to request deletion of your data if
a) the personal data is no longer necessary for the purpose(s) that it was collected for; or
b) withdraw your earlier consent to process your personal data and the data processing has no other legal basis; or
c) you object to the processing of your personal data;
d) your personal data are not processed in a lawful way; or
e) if the deletion of your personal data is justified by compliance with laws.

If you wish to have the personal data we store deleted, please contact the Data Controller at any of the contact details listed in Point 2.

Right to restrict data processing
You may restrict the processing of your personal data if
a) if you believe that the personal data stored in relation to you are not accurate; or
b) if the processing of personal data is not executed in a lawful fashion, but rather than requesting them to be deleted you wish to restrict their processing; or
c) we no longer need the personal data for the purpose(s) that we originally collected them for, you however wish to have these data for the purpose of lodging or enforcing a claim or to object to a particular claim or
d) you objected to the processing of your personal data and you are waiting for confirmation whether your interests related to the objection overrule the legal basis of the data processing.

Should you have the intention to request the restriction of the processing of your personal data, please contact the Data Countroller at any of the contact details listed in Point 2.

The right to object
You may always object to the processing of your personal data. Should you have the intention to object, please contact the Data Countroller at any of the contact details listed in Point 2.

Should any of your rights be denied, or if you are not satisfied with the answer you received from us, then you may enforce your right to the protection of your personal data before a civil court, further you may turn to Nemzeti Adatvédelmi és Információszabadság Hatóság (National Data Protection and Freedom of Information Authority) (address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; Postal address: 1530 Budapest, Pf.: 5.; phone number: +36 (1) 391-1400; e-mail address:

Date: May 25, 2018, Budapest