Privacy Policy

This privacy policy sets out how Cullinan Property uses and protects any information that is held by Cullinan Property.
Cullinan Property is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Cullinan Property may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from the 1^stof June 2018.

Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we hold.

Controlling your personal information
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

1. WHO ARE WE?

This Site is operated by Eco-Pannon Investment Kft. trading as ‘Cullinan Property’; a company registered in Hungary under registration number 01-09-302771 and our registered address is 2730 Albertirsa, Tessedik utca 17. (VAT number 26116789-2-43) (“we” “us” and “our” being interpreted accordingly).

The data controller responsible for your personal data is Eco-Pannon Investment Kft. trading as ‘Cullinan Property’ with whom you contract as a customer, member or membership applicant (“Cullinan Property”, “we”, “us” and/or “our”).

2. WHAT IS THIS PRIVACY POLICY IS FOR?

This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of this Site or as a membership applicant, member or customer (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which will become applicable to us and you as of 1^stJune 2018.

‘Personal data’ as used in this Privacy Policy means any information that relates to you from which you can be identified.

By using our Site or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

3. PERSONAL DATA WE COLLECT

We collect the following personal data about you:

• Registration: The personal details you provide when submitting a membership application. This includes your name, address, e-mail address, phone number and other information that you elect to provide to support your application.
• Investment enquiry: Proof of identity, Proof of address and Proof of funds documents required to provide (only when requesting a purchase).

4. HOW WE USE YOUR PERSONAL DATA

We use your personal data in the following ways:

• To acknowledge, confirm and deal with your membership application to the Private Investment Club (and where necessary put you on our waiting list). Such use of your data is necessary in order to implement your request to become a member.
• Eco-Pannon Investment Kft. trading as ‘Cullinan Property’ may provide you or permit selected third-party service providers to provide you, with information about goods or services and events we feel may interest you as a member when requesting business trip to Budapest. We will contact you by email only with your consent, which was given at the time you provided us with the personal data.
• As necessary for certain legitimate business interests, which include the following:

o where we are asked to deal with any enquiries or complaints you make.

o if you ask us to delete your data or to be removed from our website and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.

o to (a) comply with legal obligations, (b) respond to requests from competent authorities; enforce our members club rules; (d) protect our operations or those of any of our affiliated businesses; (e) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f) enforcing or defending legal rights or preventing damage.

As used in this Privacy Policy, “legitimate interests” means the interests of Eco-Pannon Investment Kft. trading as ‘Cullinan Property’ in conducting and managing our organisation. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent, or those activities are otherwise required or permitted to by law.

5. DISCLOSURE OF YOUR INFORMATION

We share your personal data with third parties in the following situations:

• Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms & Conditions,Club rules orother applicable contract terms that you are subject to or (iii) to protect us, our members, membership applicants, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

6. SECURITY

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

7. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.

8. CONTACT

Questions, comments or requests regarding this Privacy Policy should be addressed to info@cullinanproperty.com.