Draft prepared for legal review. Complete the marked controller and provider details and obtain professional approval before publication.
1. Controller and contact details
- Controller
- Hegedűs Károly egyéni vállalkozó
- Registered address
- 1171 Budapest, Tápióbicske utca 55., 1. em. 3/A., Magyarország
- Registration number
- 57162975
- Tax number
- 58978357-1-42
- EU VAT number
- HU58978357
- Privacy contact
- info@ingatlanvitrin.hu
- Data Protection Officer
- No data protection officer has been designated.
This Policy covers the IngatlanVitrin marketing site, app.ingatlanvitrin.hu, property and portfolio pages created by customers, the CRM, and the optional Google, Meta, payment, email, media and measurement integrations.
2. Roles and affected persons
IngatlanVitrin is an independent controller for account administration, contracting, billing, platform security, its own logs and support. For property, media, inquiry and CRM data uploaded or collected for a customer organisation, that organisation normally determines the purpose and legal basis and IngatlanVitrin acts as its processor. The actual estate agent or agency must be identified on the public page and in the relevant form notice.
Customers may only upload lawfully obtained, necessary data. They must provide notices, define retention and legal bases, and must not repurpose an inquiry for advertising without a separate valid basis. Processing on behalf of customers is governed by an Article 28 data processing agreement.
3. Processing overview
| Process | Data | Purpose | Legal basis |
|---|---|---|---|
| Security and web logs | IP, time, URL, browser/device, response and security events | Delivery, diagnostics and abuse prevention | Legitimate interest; contract where technically necessary |
| Registration and account | Name, email, phone, password hash or Google account identifier, verification, membership, role and accepted legal-document evidence | Create and secure the account; contract evidence | Contract, legal obligation and legitimate interest |
| Property, portfolio and media | Listing data, address, coordinates, price, images, floor plans and contact details | Create and publish property pages | Contract; customer-selected basis for uploaded personal data |
| Inquiry and CRM | Name, email, optional phone, message, source, property, status, notes, tasks and history | Respond to the request and manage the customer relationship | Pre-contractual request; documented legitimate interest; consent where appropriate |
| Payment and accounting | Plan, amount, currency, transaction and billing data; no card number is stored by IngatlanVitrin | Payment, access and accounting | Contract and legal obligation |
| Email and support | Recipients, content, delivery events, request, screenshots and technical records | Transactional notices, support and claims | Contract, legitimate interest and legal obligation |
| First-party analytics | Property event, time, source and daily HMAC visitor identifier | Customer statistics and abuse prevention | Contract and documented legitimate interest |
Legitimate interests are limited to platform and account security, fraud prevention, necessary claim evidence, diagnostics and proportionate service improvement. They are subject to a documented balancing test, access controls, short retention and the right to object. They do not automatically cover direct marketing.
Mandatory fields are marked on each form. Registration cannot be completed without name, email, a password or Google authentication, and the required contractual declarations. An inquiry cannot be forwarded without name, email and message; phone is optional. Refusing an OAuth permission only disables that integration. Marketing consent is always optional.
4. Public inquiries and CRM
The layered form notice identifies the actual agency or agent, purpose, mandatory and optional fields, IngatlanVitrin as processor, and links to this Policy and deletion instructions. Submission is not a newsletter or general marketing opt-in. Manually entered data must be lawful, necessary and free from sensitive, identity-document, child-related, insulting or discriminatory content.
Where data is received indirectly, the controller must provide Article 14 information, including the source, at the latest at first communication or within the applicable statutory period.
5. Meta Lead Ads integration
5.1 Purpose and permissions
5.2 Data minimisation and mapping
Data processed through the Meta connection
The system may process identifiers and necessary names for the Meta user, Page, Instagram account, business portfolio, ad account, catalogue, feed, Instant Form, campaign, ad set, creative and ad; the customer-entered budget, dates, country-level targeting, creative snapshot and approval evidence; granted, declined or expired permissions; token and data-access expiry; and sync/error status. Tokens and settings are encrypted. Only recognised lead fields are imported; unknown answers are discarded. A lead is imported only when its form is mapped to a property in the customer's organisation.
5.3 Roles, use restrictions and notice
The advertiser operating the Instant Form is the controller for business use of the lead. IngatlanVitrin processes it on the advertiser's instructions and is a controller only for its integration security and accountability records. The advertiser must identify itself, the purpose, basis, retention, recipients and appropriate privacy URL in the Instant Form.
IngatlanVitrin does not sell Meta lead data, disclose it to data brokers, use it for another organisation's advertising, enrich unrelated profiles, or use it for surveillance, credit scoring, discrimination or training general-purpose AI. Access is limited to authorised members of the receiving organisation and necessary processors.
Where the Instant Form did not already provide all Article 14 information, the system sends or includes in the first CRM communication a notice naming the data source, form/property context, controller, purposes, rights and links to this Policy and deletion instructions.
5.4 Disconnect and deletion
Normal disconnect revokes access and deletes local tokens and settings but does not by itself erase leads already lawfully stored in the customer's CRM. A signed Meta deauthorization or data-deletion callback starts a targeted process: integration access and attributable Meta inquiries/activities are deleted, and a contact is deleted automatically only if no independent source, task or activity remains. The callback returns a confirmation code and public status URL.
5.5 Facebook Page post creation, scheduling and statistics
Facebook Page publishing is an optional feature separate from the advertising and lead connection. It is currently restricted to authorised platform administrators for testing and rollout. Publishing permissions are requested through a separate Facebook connection; the existing advertising connection does not request the new publishing permissions. This feature publishes to manageable Facebook Pages selected by the user, not personal profiles or Facebook Groups. Instagram publishing is not provided.
Data and purposes: the connected Meta user ID; IDs and names of Pages made available by Meta, Page tasks, selected Pages, granted permissions, tokens and expiry; post title, text, link, images, selected property and necessary property snapshot; author and organisation IDs, schedule, time zone, delivery status, published post ID/link, and events necessary for delivery, troubleshooting and duplicate prevention. Processing supports connection, content preparation, scheduling, publication and status tracking. Technical connection data for available but unselected Pages may also be stored so they can be selected later; the system does not publish to unselected Pages.
Images and publication: users may select their uploaded images, property images or completed marketing images. Private delivery copies and checksums are created. A draft is not a publication instruction; selecting immediate or scheduled publication instructs delivery to the specified Page. Approved text, links and images are transmitted to Meta; images for a multi-image post may be uploaded before the final post is created. Published content becomes available to others according to the Page's and Meta's visibility rules. The user is responsible for lawful publication of images and personal data in the content. Publishing does not initiate paid advertising or ad spending.
Statistics: for posts published through IngatlanVitrin, the system stores aggregate reaction, comment and share counts, a supported view metric where available from Meta, retrieval timestamps and availability status. It does not import comment text or individual reactor/commenter profiles, build individual profiles from these statistics, or automatically import all historical Page posts. Missing or unsupported metrics are not estimated or treated as zero.
Roles, lawful basis and recipients: the user or organisation determines the purpose and appropriate lawful basis for personal data in the content. IngatlanVitrin acts as processor in technically carrying out these instructions and as controller for its own account, access and security data as described in sections 2–3. Providing the requested service relies on contract performance; necessary security events rely on documented legitimate interests; uploaded content requires the customer's appropriate lawful basis. Recipients include Meta Platforms Ireland Limited and affiliated providers under its product terms, and the Facebook audience for published content. Technical processors and transfers outside the EEA are covered in sections 10–11. Tokens are encrypted and access is scoped to the user and organisation. Optional AI text suggestions use necessary selected-property data under section 8; Meta tokens and post statistics are not sent to the text-suggestion provider.
Disconnect, retention and deletion: the publisher's disconnect action deletes publishing tokens and disables further publishing/statistics refresh without disconnecting the separate advertising connection. Deselecting a Page does not delete its Facebook content or local history; pending posts require rescheduling. A provider request already started cannot reliably be cancelled. Drafts, scheduling/publication history, statistics and related image copies are processed during the active service and the account-retention period of up to six months described in section 12; earlier deletion may be requested under the Data Deletion Instructions and section 13. Meta app deauthorisation also disables publishing access. A valid Meta data-deletion request triggers targeted deletion of local publishing records, statistics and image copies attributable to that connection. Original property data and images lawfully held for other purposes are not automatically deleted. Local disconnect or deletion does not remove posts or images already stored on Facebook; these are managed on Facebook under Meta's own privacy rules. Backup rotation is described in section 12.
6. Meta Pixel, catalogue and app measurement
Meta Pixel is separate from Lead Ads and is loaded only after marketing consent. Customers may configure their own Pixel for property-page PageView, Lead, phone and email click measurement. IngatlanVitrin may separately configure its own Meta Pixel, Google Tag Manager and Google Analytics for the application. The platform and customer identifiers remain distinct. Personal form values must not be sent as measurement parameters.
An optional Meta property catalogue may expose published listing IDs, descriptions, prices, parameters, locations, URLs and images through a secret rotatable feed; it contains no inquiry data. At the customer's request, IngatlanVitrin may use the Catalog API to create or connect the catalogue and its daily data feed. On disablement, the customer must also check copies and objects retained in Meta Commerce Manager.
7. Sign in with Google, Google Calendar and Limited Use
7.1 Sign in with Google
A user may choose “Continue with Google” to sign in or register. IngatlanVitrin requests only the basic openid, profile and email permissions and receives the stable Google account identifier, display name, email address and email-verification status. The purposes are user authentication, account creation and secure linking to an existing IngatlanVitrin account with the same verified email address. The legal basis is taking pre-contractual steps at the user’s request or performing the service contract.
IngatlanVitrin does not retain the access token received during Google sign-in and does not use it to access other Google services. The Google account identifier is retained as part of the IngatlanVitrin account for the account retention period. Google sign-in alone grants no Google Calendar access; Calendar is connected through a separate, explicit authorisation flow.
7.2 Google Calendar
Data processed through the Google connection
Stored data may include Google account/email, encrypted tokens, scopes, calendar names/IDs and access roles, selected target/free-busy calendars and created event IDs. Disconnect revokes/deletes tokens; events already created in Google Calendar may remain until the user removes them.
Google Limited Use: use and transfer of Google Workspace API information complies with the Google API Services User Data Policy and Google Workspace API User Data and Developer Policy, including Limited Use. Data is used solely for the user-facing calendar feature and is not sold, used for advertising, creditworthiness, or training general-purpose AI; human access is allowed only in permitted exceptional circumstances.
8. Address lookup, media and optional AI
Address queries may be sent to the configured OpenStreetMap Nominatim service; a one-way query hash and result may be cached for up to 30 days. Images and floor plans may be stored and delivered by ImageKit. Optional AI enhancement runs only on explicit request. Identity documents, special-category data, private correspondence and unnecessary metadata must not be uploaded. Deletion also requests removal of the associated ImageKit file; CDN copies expire within a technical cache period.
When a public property page is opened, its interactive OpenStreetMap map and, if configured for the property, its YouTube walkthrough video load automatically. The visitor's browser may therefore connect directly to OpenStreetMap and YouTube, which may receive technical connection data including the IP address, browser data and referring page. Videos use YouTube's privacy-enhanced youtube-nocookie.com domain, but this does not prevent the network connection itself.
9. Cookies and measurement consent
Strictly necessary session, security and consent technologies may operate without consent. Google Analytics 4, Google Tag Manager, Google Ads, Meta Pixel and TikTok Pixel load only after consent for the relevant analytics or marketing category. Default Google Consent Mode is denied. Equal options are provided to accept all, keep necessary only, or customise; settings can be reopened at any time. The consent cookie stores category choices and configuration version for up to 180 days. Exact names and durations are in the Cookie Policy.
10. Recipients and processors
| Provider | Function | Location/safeguard |
|---|---|---|
| RackForest Informatikai Kereskedelmi Szolgáltató és Tanácsadó Zrt., Iroda és számlázási cím: 1132 Budapest, Victor Hugo utca 11., 5. emelet, B05001. Szervertermek: 1132 Budapest, Victor Hugo utca 18–22., 3. emelet; 1087 Budapest, Asztalos Sándor utca 13.; 1108 Budapest, Kozma utca 2. | Application, database, files, logs and backups | Magyarország (EU), contract and DPA |
| Cloudflare, Inc. | DNS, network security, CDN and technical logs | DPA, SCCs and applicable transfer mechanisms |
| Brevo contracting entity | Transactional email and delivery events | DPA and current subprocessors |
| Stripe contracting entity | Checkout, payment and fraud prevention | DPA and applicable EU-US safeguards |
| ImageKit contracting entity | Media storage, CDN and requested AI processing | Selected region, DPA, SCCs and subprocessors |
| Google Ireland Limited and providers | Optional Calendar, analytics and ad measurement | Google terms and applicable safeguards |
| Meta Platforms Ireland Limited and providers | Optional Lead Ads, Pixel and catalogue | Meta terms, Data Processing Terms and safeguards |
Authorities, courts, accountants, legal representatives and other recipients receive only necessary data on an appropriate basis. Organisation members receive role-based access only.
11. International transfers
Transfers outside the EEA require a GDPR Chapter V mechanism, such as an adequacy decision, EU Standard Contractual Clauses with supplementary measures, or another valid safeguard. Information and copies of applicable safeguards may be requested through the privacy contact.
12. Retention and deletion
| Data | Retention |
|---|---|
| Active account, CRM, inquiries, properties, media and integrations | For paid access, then a six-month recovery period. Operational data is then deleted or irreversibly anonymised. |
| Accounting evidence | Normally eight years under Hungarian accounting rules, separated from the operational account. |
| Raw first-party analytics / aggregated analytics | Up to 90 days / until the active service and six-month recovery period end, or earlier true anonymisation. |
| Google sign-in identifier | Until the active IngatlanVitrin account and six-month account-recovery period end, then deleted with the account. |
| Google Calendar/Meta tokens | While connected; revoked/deleted promptly on disconnect or revocation. |
| Email, security and audit logs | Normally 90 days, longer only for a necessary incident or claim. |
| Disaster-recovery backups | 30-day rotation; completed deletions must be re-applied after restoration. |
13. Rights, marketing and remedies
Data subjects may request access and a copy, rectification, erasure, restriction and, where applicable, portability; object to legitimate-interest processing; and withdraw consent without affecting prior lawfulness. There is no solely automated decision producing legal or similarly significant effects. Requests are normally handled within one month. If IngatlanVitrin is a processor, it forwards the request to and assists the actual controller.
Electronic direct marketing requires separate, voluntary, prior and provable consent. Registration, Terms acceptance, inquiry submission and marketing consent are separate. Consent source, time and text/document version may be logged; every marketing message and the account must offer easy withdrawal.
Complaints may be lodged with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH), 1055 Budapest, Falk Miksa utca 9–11, Hungary; ugyfelszolgalat@naih.hu; naih.hu. Judicial remedies remain available.
14. Security and incidents
Controls include HTTPS, role-based access, organisation isolation, secure password hashing, encrypted OAuth tokens/settings, webhook-signature validation, rate limiting, logs, backups and updates. Incidents are investigated, mitigated and documented, with supervisory-authority and high-risk data-subject notifications made where required.
15. Children and sensitive data
The service is for business users and is not directed at children. CRM, forms, Meta Lead Ads and media features must not be configured to routinely collect children's data, special-category data, criminal data or other unnecessary sensitive information.
16. Changes and accountability
The version and effective date appear above. Material changes are announced in-app or by email. Registration records the acknowledged policy version and content hash. Before adding a new purpose, category, integration or recipient, the notice, records, risk assessment and consent configuration are reviewed.