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TERMS OF USE AND DATA PRIVACY NOTICE
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TERMS OF USE AND DATA PRIVACY NOTICE
The website https://grand-development.hu (hereinafter: Website) is operated by KOKSI HOLDING LTD (seat: 4 Annis Komninis, Solea Building, Office 202, 1060, Nicosia, Republic of Cyprus; company reg. nr.: Cg.HE 343377; repr. by: Julija Jasina director) (hereinafter: „Company” or „Data Controller”). Please read carefully the following Website Terms of Use and Data Privacy Notice (hereinafter: Notice), which apply to all visitors to the Website. By loading and using the Website, you give your consent to the fact that this Notice and its amendments in effect at the time of your visit are binding on you and you undertake to comply with them. If you do not agree with the Notice, please do not use the Website. The Company may modify this Notice at any time, even without your express notification, by updating its text, and because such modifications are also binding on you, we recommend that you check the Notice again from time to time. The present Notice is effective from on Ocrober 10, 2023. 


I. Copyright


1. Terms of use


The content of this Website is the property of the Company and is protected by copyright. The use of the documents and other data, recordings, and images on the Website for any purpose, as well as the use of other content of the Website (especially the videos on it) is strictly prohibited and may result in civil or criminal consequences. Violators of the law will be prosecuted. No commercial name, brand name, logo, graphic, sound or image on the Website may be copied or forwarded without the express prior approval of the Company.

2. Copyright warning


Copyright © 2023 KOKSI HOLDING LTD. All rights reserved!
We reserve the rights not granted to others.


II. Liability regulations


1. Legal notice


We have made every effort to publish correct and up-to-date information on the Website. However, the Company does not guarantee the suitability of the information contained in the documents and the associated visual elements for any purpose. All documents and images are provided without liability. All types of access and use of the data, as well as their content, are the responsibility of the user. In no case can the Company be held responsible for direct or indirect damage, or for loss of data, profit and opportunity to use, regardless of whether this is due to compliance with contractual points, negligence, or as a result of other unlawful acts, which occur from the using or passing on of the information on the Website.  All information on the Website is for informational purposes only and cannot be considered as an invitation to invest, an advertisement or a public offer. The documents and image elements on the Website may contain inaccuracies or typos. We change the information here regularly. Since the Company cannot guarantee the continuous operation of its server or the server's Internet connection, nor can it exclude the possibility of third-party access to the server, the Company is not liable for any damage resulting from the possible failure or unavailability of the server or changes to the content of the Website by a third party.

2. Links to other websites


By clicking on certain links on the Website, you will be leaving the Website. The referenced websites do not fall under the authority of the Company, the Company assumes no responsibility for the content of the referenced pages, for the links found on them, or for changes made to these websites. The links are provided solely to facilitate the use of the Website, providing them does not mean the support of the Company.


III. Use of the Website


1. General rules for the use of the Website


When using the Website, certain data, such as the information transmitted by your browser (IP address, cookies, the referring website, date and time, the viewed content) may be saved. If this information is considered personal data, then - unless you have authorized a different use - such data will be used exclusively for the use of the Website (including maintenance purposes, e.g. preventing attacks), statistical purposes, marketing purposes authorized by you and/or we use it to fulfil the agreement concluded with you, including requests for information and sending newsletters as requested by you.

2. Further rules


By using the Website, you accept this Notice and consent to the processing of your data for the purposes specified here.  The person using the Website is responsible for the accuracy and truthfulness of the personal data provided during the login to the Website. You can find more information on the use of your data and the related data subject’s rights in the "privacy notice" section. 

3. Questions and feedbacks


The content of questions and answers related to the Website is not considered confidential; the Company has no obligations regarding the answers, it can freely use, disclose and distribute them to others.  A record may be made of the use of the Website. The Company can use this information for statistical purposes, which can improve the operation of the Website and the quality of the service it provides. If you do not accept the Notice, please do not use the Website.

4. Purpose of the Website


The purpose of the Website is to provide information about the real estates marketed by the Company (including, in particular, the marketed apartments and other premises, parts of real estate), to support the Company’s sales activity by publishing information and other materials.


IV. Privacy notice, cookies


The Company takes the protection of your personal data very seriously. The nature, scope and purpose of the collection and processing of personal data depends on the activity performed by the user during his visit to the Website. At the same time, personal data is collected and processed in all cases exclusively in accordance with the relevant legislation. The following provisions apply to the use of personal data.

1. Data Controller’s data


company name: KOKSI HOLDING LTD
seat: 4 Annis Komninis, Solea Building, Office 202, 1060, Nicosia, Republic of Cyprus.
company reg. nr.: HE 343377
represented by: Julija Jasina director

e-mail: sales@astora.hu
tel.:  +36 30 302 7970

If you have any questions or comments regarding this Notice or the handling of your personal data, please feel free to contact us at any of the above contact details.

2. General regulations


The definitions applied in this Notice comply with the rules of law in effect, including in particular: the definitions described in Regulation (EU) 2016/679 of the European Parliament and of the Council 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 – hereinafter referred to as: GDPR) and in Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter referred to as: Privacy Act).

When performing data processing, the Data Controller shall act in full conformity with the prevailing regulations.

3. Specific uses of personal data regarding the use of the Website


The use of the Website or any other personal data processing in connection with the Website by the Data Controller is based on the prior consent of the Data Subject (manifested either in the use of the Website or as an active action).

a) Purpose, legal basis and length of the data processing:



Purpose Affected data Legal basis Retention time
request of information from the Data Controller Data specified by you in the information request, e-mail address consent (GDPR article 6. point (1) a)) Until the withdrawal of the consent, but not longer than the provision of the answer, unless the Data Controller continues to process the data based on another legal basis, about which you will be informed.
newsletter subscription E-mail address consent (GDPR article 6. point (1) a)) Until revocation of the consent.
cookies for detailed information, please check the article on cookies


Possible legal consequences of refusing data management/contribution: failure to provide relevant information, failure to respond in the event of a request for information, newsletter not being sent. As a general rule, the provision of data is not a prerequisite for concluding a contract.

b) Data transfer, access, data storage:


We may share personal information with third parties as follows:

i. Service providers, subcontractors


In order to manage personal data in the manner described in this data privacy notice, we use external service providers. These service providers process the data for us on the basis of the instructions received from us and under our supervision, according to what is written in the data privacy notice.

The service provider is (hosting provider, data processor): name: KOKSI HOLDING LTD (seat: 4 Annis Komninis, Solea Building, Office 202, 1060, Nicosia, Republic of Cyprus; company reg. nr.: Cg.HE 343377; repr. by: Julija Jasina director; tel.: +36 30 302 7970; e-mail: sales@astora.hu)

Hosting activities: Hetzner Online GmbH (seat: Industriestr. 25, 91710 Gunzenhausen, Germany; Tel.: +49 (0)9831 505-0; Fax: +49 (0)9831 505-3; E-Mail: info@hetzner.com; Ansbach Registration Office, HRB 6089; VAT Reg. No. DE 812871812; CEO: Martin Hetzner, Stephan Konvickova, Günther Müller).

ii. Transfer of data to a receiving party outside the European Union


Data transfer to a third country can only take place based on a compliance decision, appropriate corporate guarantees, general data protection clauses or deviations provided by law for the given situation, and ultimately with the Data Subject's consent. The Data Controller bears full responsibility for the legality of the data transfer and the security of the data.

iii. Data transfer


The Data Controller does not sell, share, forward or lease the information obtained through the Website, excluding any data processing activities carried out by data processors.

iv. Data security


Data Controller takes care of default and built-in data protection. To this end, the Data Controller applies appropriate technical and organizational measures in order to:

  • accurately regulate access to data;
  • allow access only to persons who need the data in order to perform a given task with it, and even then only the data that is minimally necessary to perform the task can be accessed;;
  • carefully select the data processors it commissions and ensure the security of the data with an appropriate data processing agreement;;
  • ensure the immutability (data integrity), authenticity and protection of the processed data.;

v. Physical storage of data


Hungary/EU.

4. Cookies


Some applications of the Website contain small text information files, so-called cookies, which are stored on the visitors' hard drives and collect anonymous data in order to facilitate user identification and further visits. The user of the page can determine whether he wants to accept cookies or not, and whether he can receive a notification if the viewed page sends him a cookie.

During browsing, your IP address, your browser type, and the assigned so-called cookie ID are logged. We store and process this data for the maintenance of the Website, the display of its statistical data, and the development of the Website.

If you give permission for this, you consent to the use of the information transmitted in this way by the Website for the purpose of operation. Remember, if you change this setting, i.e. you do not allow cookies to be accepted, in that case some services of the Website will not be available or will be limited.

The cookie in itself cannot identify the visitor in any way, it is only suitable for recognizing the machine of the returning visitor.

If you would like to limit or block cookies installed by the Website, you can do so through your browser settings. Your browser's Help application will explain exactly how. We also recommend the website www.aboutcookies.org, which provides detailed and comprehensive information on the settings of many browsers. Here you will find general information about cookies, as well as a description of how they can be deleted from your computer. Regarding mobile phones, you can find more information about all this in the operating instructions and user instructions.

Please note that restricting or banning cookies may affect the operation of the Website.

a. Targeting and marketing cookies


The purpose of these cookies is to display advertisements on websites that are of interest to or relevant to the user.

We use marketing cookies that allow us to follow users to other websites and to display ads that are relevant and attractive to each user. This processing is based on your consent (GDPR Article 6(1)(a)), which you can withdraw at any time, with future effect and without any disadvantage, by changing your settings on this link.

Name of the cookie Tpye of cookie Purpose and data used Legal basis
Google Analytics Cookies used by the Data Controller's service providers (third party cookie). The purpose of these cookies is to obtain aggregated data from the use of the Website by the users, to improve the content and format of the Website for better efficacy. consent (GDPR article 6. point (1) a))
Google ads Cookies used by the Data Controller's service providers (third party cookie). The purpose of cookies is to measure the effectiveness of advertisements and to display targeted advertisements to users. More information: business.safety.google/adscookies/ consent (GDPR article 6. point (1) a))
Google Tags Manager Cookies used by the Data Controller's service providers (third party cookie). The purpose of cookies is to identify the individual user during browsing. More information: https://developers.google.com/tag-platform/devguides/cookies consent (GDPR article 6. point (1) a))
Facebook pixel cookie Cookies used by the Data Controller's service providers (third party cookie). The purpose of the cookie is to provide you with information tailored to your interests when you visit Facebook or a third-party website. More information: https://www.facebook.com/privacy/policies/cookies consent (GDPR article 6. point (1) a))
Instagram pixel cookie Cookies used by the Data Controller's service providers (third party cookie). The purpose of the cookie is to provide you with information tailored to your interests when you visit Instagram or a third-party website. More information: https://help.instagram.com/1896641480634370 consent (GDPR article 6. point (1) a))

b. More information related to Facebook and Instagram pixel cookies:


If and as long as you consent, we use cookies provided by Meta Platforms Ltd., 5-7 Hanover Quay 2 Dublin, Ireland (“Facebook” and “Instagram”) in connection with the Facebook and Instagram web marketing services. When you visit our website and perform an activity (e.g. download a document), the Facebook and Instagram pixel is activated and will report this action. We sort this information. In this way, we can use advertising functions such as audience, conversions, targeted advertising and optimization, as well as analytics data from Facebook and Instagram. This means that when you visit Facebook and Instagram or a third-party website, you will receive information tailored to your interests. It is in our interest to provide you with information based on your interests, so that our Website and the information we provide continue to be of interest to you.

We have no influence on the specific direct use or further use of your data by Facebook and Instagram. To the best of our knowledge, we inform you of the following: Through the Facebook and Instagram pixel, Facebook and Instagram receive information that you have visited our Website or clicked on one of our advertised messages. If you have registered for a service of Facebook and Instagram, Facebook and Instagram will be able to link your visit to your account. Even if you have not registered or logged in to Facebook, Instagram, Facebook and Instagram can track your IP address and/or other identifying information.

In the event that your data leaves the European Union, Facebook and Instagram have self-certified compliance with the EU-US Privacy Shield (as you can also see here). For more information on data processing by Facebook and Instagram, please visit https://www.facebook.com/about/privacy and https://privacycenter.instagram.com/policy.

c. Social plugins


We integrate social plug-ins (“Plugins”) from Meta Platforms Ireland Ltd, 5-7 Hanover Quay 2 Dublin, Ireland (“Facebook” and “Instagram”) and other providers on our Website to enable you to interact with the content we display (for example by "liking").

In order to protect your personal data, we have incorporated the so-called Shariff solution: Only when you click on the social media provider's button on our website (for example, the Facebook "like" button), your browser establishes a direct connection with the provider's server, which is located in the USA. If you are logged into your user account with the respective provider, this may add additional insight into your profile data about your use of the content we display. The service provider is responsible for processing your personal data (including the data listed in section 2.1 of this privacy statement). You can find more information about the processing of personal data on the service provider's website. The legal basis for the use of plug-ins is provided by Article 6 (1) point a) of the GDPR.

Please note that we have no influence over the data processing activities of Facebook and Instagram, nor are we aware of the full scope and purposes of the processing, as well as its duration. More information on the purpose and scope of data collection and processing by Facebook and Instagram can be found on the pages of the respective service providers, please visit https://www.facebook.com/about/privacy and https://privacycenter.instagram.com/policy.

5. Rights of the data subjects


With regard to the data processing, the Data Subject has the following rights:

  • Right to receive transparent information: prior and during the data processing, the Data Subject has the right to receive information of the data processed and also of the data processing itself; the present Notice is also part of such information;
  • Right to have access to the data stored: The Data Subject is entitled to request information of the data stored regarding them and the individual components of the data processing (in particular: the existence, purpose, legal ground of the data processing, the scope of processed data, data transfer to third persons, period of storing the data, method of exercising the rights, possible legal remedies, data source, profiling, automated decision-making, guarantees, etc.);;
  • Right to rectification: in case of erroneous data, the Data Subject may initiate the rectification of the data;;
  • Right to erasure (be forgotten): the Data Subject may ask the erasure of the data if:;
    • the data are not needed for the original purpose, for which they were collected;
    • the Data Subject withdraws its consent to the data processing
    • the Data Subject objects to the data processing and there is no other reason and legal ground for the data processing
    • the data processing is illegitimate
    • legal obligation requires the erasure
    • the data collection took place in relation to offering any service connected to the information society;
  • Right to object: the Data Subject may object to the data processing if it is based on a public or legitimate interest; in such a case, the Data Controller is entitled to continue the data processing only in the event that it is justified by such compelling legitimate interest that have priority over the Data Subject or are connected to a legal claim enforcement. Objection to data processing for direct marketing purposes can be submitted any time, and in case of objection for such a reason, the data processing shall not be continued;
  • Right to restriction of data processing: in the event of unlawfully processed data or in any other case allowed by the law, the restriction of data processing can be requested,
  • Right to data portability: in the case of data processing carried out by automatic data processing which is based on consent or contract, the Data Subject is entitled to request the surrender of the data provided by them in a structured, commonly used, machine-readable format and they can transmit those data at their own discretion;
  • Right to withdrawal: the Data Subject may withdraw their consent any time.


The Data Subject can exercise their rights any time. The Data Subject can send the request for it to the e-mail address sales@astora.hu or to the following mail address: 1131 Budapest, Jász utca 139. Data Controller informs the Data Subjects that, pursuant to the legal regulations in effect, it is not obligated to appoint a data protection officer, but an appointed data protection coordinator is at the disposal of the Data Subjects at the above contact details.

The Data Controller is entitled to identify the Data Subject before giving any reply (in order to check whether the request came from the eligible person). The Data Controller considers the contacts received from the e-mail address of the Data Subject registered by the Data Controller that they come from the Data Subject. In the case of requests received in any other form, the Data Controller is entitled to verify the Data Subject in another way (e.g. to inquire about the truthfulness of the written request orally on the telephone number provided, to require written confirmation of an oral request, or to initiate any other adequate identification).

The Data Controller will check the requests received and arranges them without delay but not later than within one month, in exceptional cases in a longer term allowed by law, or rejects them (with explanation). The Data Controller will inform the Data Subject of the result of the decision in writing. Solving the request is free of charge, except for unfounded or exaggerate requests, for the solving of which the Data Controller is entitled to charge a reasonable fee complying with its administration costs.

The Data Subject can submit comments or complaints any time against the data processing at the Data Controller at the above-mentioned contact details. In addition, the Data Subject is entitled to initiate a legal proceeding at the court seated at the place of residence of the Data Subject, which proceeding is free of duty and in the course of which the court will give priority to the proceeding. In addition, the Data Subject may submit a complaint to the Hungarian National Authority for Data Protection and Freedom of Information.

In the course of data processing, the accuracy and completeness of the data must be ensured and, if necessary with regard to the purpose of the data processing, their updating. For this purpose, the Data Controller requests the Data Subjects to inform the Data Controller of any change in their personal data registered by the Data Controller as soon as possible.
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