DATA PROCESSING INFORMATION

Effective: From January 11, 2026 until revoked.

The purpose of this Data Processing Notice is to inform visitors to https://k4lofts.hu (hereinafter: Website) (hereinafter: Data Subject) about the processing of personal data and the related rights and obligations. Data processing is carried out in accordance with Act CXII of 2011 (Info tv.) and Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).

1. Data Controllers' details

A. Primary Data Controller Who is the owner of the real estate development and the controller of the contact details:

  • Company name: Városmag KE4 Kft.

  • Registered Seat: 1053 Budapest, Kecskeméti utca 4.

  • Company registration number: 01-09-329064

  • Represented by: András Ifi, managing director

  • Email: info@k4lofts.hu

  • Phone number: +36 30 664 6665

B. Joint Data Controller and Marketing Partner Who handles marketing communications for the real estate development project and brokers real estate market offers in its own right:

  • Name: Ur Máté sole proprietor (Unbuiltmarket)

  • Headquarters: 7632 Pécs, Tildy Zoltán Street 31, 6th floor, door 20.

  • Tax number: 90191424-1-22

  • Email: uma@unbuiltmarket.com

The Data Controller reserves the right to unilaterally amend this Notice. The Data Controller shall inform the Data Subjects of any amendments via the Website.

In the case of data processing for marketing purposes – which is subject to acceptance of a separate checkbox on the Website – data processing is carried out jointly by Városmag KE4 Kft. and Ur Máté e.v. as joint data controllers. For all other data processing purposes (contacting us, requesting a quote, communication related to a specific real estate development project), the data controller is exclusively Városmag KE4 Kft.

2. Purpose of data processing

  1. Contact and quotation: Ensuring that visitors to the Website can request quotations for real estate development services, receive customized quotations, and contact the Data Controller.

  2. Marketing and Newsletter (Optional): If you select the option "Would you like to be the first to hear about future projects?", you consent to Városmag KE4 Kft. and its sales partner, Unbuiltmarket (Ur Máté e.v.), sending you notifications. The purpose of joint data processing is to ensure that you do not miss out on any opportunities. By subscribing, you consent to:

    • Városmag KE4 Kft. will inform you about the new phases of the current project (K4 Lofts) and its own investments.

    • As a real estate market expert, Unbuiltmarket will send you similar, high-quality new-build property development offers and investment opportunities available on the market.

    • You may withdraw your consent at any time without giving any reason by clicking on the unsubscribe link at the bottom of the newsletters.

  3. Analytics and optimization: Website traffic analysis and advertising conversion measurement for service development and optimization.

Within the framework of joint data processing, Városmag KE4 Kft. is responsible for the legal basis of data collection and for ensuring the rights of data subjects, while Unbuiltmarket (Ur Máté sole proprietorship) is responsible for the technical implementation of marketing communications and the operation of data processing systems. Data subjects may exercise their rights with any joint data controller.

3. Scope of personal data processed

The scope of personal data collected through the Website (forms):

  • Full name

  • E-mail address

  • Phone number

Data collected during technical measurements (see points 6-7):

  • IP address, browser data, cookie identifiers.

4. Legal Basis for Data Processing

  • Consent of the data subject (Article 6(1)(a) of the GDPR): given by accepting the request for quotation, contacting us, or accepting the cookie banner on our website. The legal basis for data processing for marketing purposes is also the voluntary, explicit consent of the data subject, which applies to joint data processing.

  • Performance of a contract or steps prior to entering into a contract (Article 6(1)(b) of the GDPR): in the case of a request for quotation.

  • Compliance with a legal obligation (GDPR Article 6(1)(c)): e.g., for billing purposes.

Providing the data necessary for contact does not constitute data processing for marketing purposes and is not related to accepting the checkbox for marketing purposes.

5. Duration Data Processing

We store the data for 12 months from the date of the request for quotation or until the Data Subject withdraws their consent. In the case of data processing for marketing purposes, we store the data until you unsubscribe.

6. Data processors and third parties (Technical partners)

Marketing-related email communication is carried out through systems used by Városmag KE4 Kft. and Unbuiltmarket (Ur Máté sole proprietorship). We use the following third-party service providers (data processors) to operate the Website and perform measurements. The Data Controller declares that its partners comply with the provisions of the GDPR.

A. Website features:

  • Squarespace Ireland Ltd.: Website hosting (storage) and cookie consent management (built-in cookie banner).

  • Google Maps: Map display.

  • Kuula: 360-degree real estate tours.

  • Apartmentpicker: A self-developed apartment selection application embedded from GitHub.

B. Analytics and Advertising Measurement (Server-Side Tracking): We use Server-Side Tracking to measure website traffic and advertising data more accurately.

  • Stape Europe OÜ: (Headquarters: Estonia, Server location: EU/Germany). Technical service provider for server-side measurement (proxy server). Transfers data from the website to advertising partners via a secure channel.

  • Meta Platforms Ireland Ltd. (Facebook): Facebook Pixel and Facebook Conversions API (CAPI) services.

    • Purpose of data transfer: Measuring the effectiveness of advertisements, remarketing.

    • Processed data: IP address, browser data, and, in the case of a request for a quote, the user's encrypted (hashed - SHA256) email address and phone number (Advanced Matching).

  • Google Ireland Ltd.: Google Analytics 4 and Google Tag Manager services for statistical purposes.

C. Sales Partners and Data Transfer When you fill out certain request forms on the Website (which are accessible via a special link, e.g., partner code), the contact details you provide (name, email, phone number) may be transferred to real estate sales partners contracted by Városmag KE4 Kft.

  • Purpose of data transfer: Direct sales information and appointment scheduling related to the property you are interested in.

  • Recipient of data transfer (Partner office):

    • Name: UNIQUE HOMES

    • Representative: György Nagy

    • Headquarters: 8600 Siófok, Jubileumi tér 6.

    • Web: unique-homes.hu

    • Email: info@unique-homes.hu

    • Tel: +36 30 387 4677

Important restriction: The Sales Partner may only process your data in connection with the specific offer. If you subscribe to our newsletter by checking the marketing checkbox on the Website, you give this consent exclusively to Városmag KE4 Kft. and its marketing partner, Unbuiltmarket. The Sales Partner does not receive marketing authorization and cannot send you independent newsletters based on this consent. Technical background: The data received from the forms is stored in a secure cloud-based storage (Google Drive / Google Sheets) managed by Unbuiltmarket, to which the Sales Partner has limited access (only for its own customers).

7. Use of Cookies and Server-Side Measurement

The Website uses cookies to improve its functionality and user experience. Cookies are managed using Squarespace's built-in consent management tool.

Important: The Facebook Conversions API (server-side measurement) and marketing cookies are only used if you have given your express consent via the cookie banner when you arrive at the website (acceptance of marketing cookies). If you reject marketing cookies, the system will not transmit any data to Meta/Facebook from either your browser or the server. Server-side measurement does not serve to circumvent consent; marketing data is only transmitted with the prior consent of the data subject.

8. Rights of data subjects

Data Subjects are entitled to request access to the personal data provided by them; request rectification or deletion of their data; object to data processing if it is unlawful or for marketing purposes; or withdraw their consent at any time. You may exercise your rights at the following e-mail address: info@k4lofts.hu

  • Request access to the personal data they have provided.

  • Request the correction or deletion of your data.

  • Object to data processing.

  • Withdraw their consent at any time (this does not affect the lawfulness of data processing prior to withdrawal).

You can primarily exercise your rights at the following email address: info@k4lofts.hu

In the case of exercising rights related to data processing for marketing purposes (withdrawal of consent, deletion, objection), the Data Subject may also request the enforcement of any of the above rights at uma@unbuiltmarket.com.

Please note that since Városmag KE4 Kft. and Unbuiltmarket also manage their own newsletter databases, unsubscribing is always done via the link at the bottom of the newsletter in question, which refers to the database of the sender in question.

9. Data security

The Data Controller shall do everything in its power to ensure the security of personal data. During server-side measurements, data is transmitted via an encrypted channel, and personal data (e.g., email) is transmitted to advertising systems in hashed form, ensuring its protection.

10. Contact person

The official representative and data protection contact person for the Controller is:

  • Name: András Ifi (Managing Director)

  • Official email: info@k4lofts.hu

  • Secondary email: ifiandras@gmail.com

Requests from data subjects should primarily be addressed to info@k4lofts.hu.

11. Complaints and Legal Remedies

Data Subjects may address their complaints regarding data processing directly to the Controller:

  • Email: info@k4lofts.hu

  • Phone number: +36 30 664 6665

If the Data Controller's response is unsatisfactory, data subjects may contact the National Authority for Data Protection and Freedom of Information (NAIH):

  • Address: 1055 Budapest, Falk Miksa u. 9-11.

  • Web: www.naih.hu

  • Email: ugyfelszolgalat@naih.hu

12. Relationship between the data controller and data processor

The Data Controller (Ifi András) and the developer and website operator, Ur Máté, who manages the technical settings (GTM, Stape), have access to the data of the data subjects.

Depending on the nature of the activity, a data processing agreement is in place between the parties, and a joint data processing agreement is in place for joint data processing for marketing purposes, which sets out the exact responsibilities and ensures GDPR compliance.

Ur Máté acts as a data processor in basic data processing operations (contacting, requesting quotes) (technical fulfillment), while in the case of data processing for marketing purposes, it is considered a joint data controller with Városmag KE4 Kft.

Date: Budapest, December 5, 2025. Modified: December 12, 2025. Modified: January 11, 2026. (Supplemented with marketing contacts and joint controller data.)