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(effective from 26 March 2026 until further notice)

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PRIVACY NOTICE

regarding the processing of personal data related to the use of the “Westend” Mobile Application and the integrated “Parking Application” service

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Introduction

The purpose of this Privacy Notice (hereinafter: “Notice”) is to ensure that natural persons using the “Westend Mobile Application” and the “Parking Application” integrated therein receive information — in accordance with applicable legal regulations — regarding the processing of personal data collected about them, including the purposes and legal bases of such processing, the identity and contact details of the Data Controller and data processors, and the essential information related to data processing.

The purpose of this Notice is also to ensure that Data Subjects:
• can become familiar with their rights related to the processing of their personal data,
• receive information about whom they may contact and in what manner with requests or questions regarding the processing of their personal data, from whom they may obtain the requested information and within what timeframe,
• know whom they may contact with a complaint and from which authority they may request legal protection if they believe their rights have been violated in connection with data processing.

In this Notice we strive to summarize the above information in a clear and transparent manner so that Data Subjects can assess how the recording, storage and other processing operations performed on their personal data may affect their right to informational self‑determination and their privacy when contacting the Data Controller, communicating with it or using the services.

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1. Identification of the Data Controller

Data Controller: Rollet Kft.
Registered office: 1046 Budapest, Szabó József u. 6.
Company registration number: 01-09-303490
E-mail address: adatvedelem@rollet.hu

Data Protection Officer: The company does not employ an independent data protection officer; however, it continuously keeps its data protection regulations up to date.

Hereinafter referred to as: “Data Controller”.

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2. Fundamental rules applicable to data processing

The fundamental legal acts governing the data processing described in this Notice are:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

  • Act CXII of 2011 on the Right of Informational Self‑Determination and on Freedom of Information (“Info Act”).

  • Act CVIII of 2001 on certain issues of electronic commerce services and information society services.

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3. Services concerned by data processing

3.1 Parking Application

The shopping centre provides multi‑level indoor and outdoor parking areas (hereinafter: “Parking Areas”) for visitors arriving by car.

The use of the Parking Areas is subject to payment. Parking or charging fees may be paid at automated payment terminals installed in the Parking Areas or at designated operator offices in cash or by bank card.

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In order to provide visitors with convenience and the possibility of fast, cash‑free payment of parking and charging fees, the Data Controller integrated a Parking Application into the Westend Mobile Application.

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Data Subjects may use the Parking Application if they:

  • create their own parking user account,

  • separately register within the Parking Application,

  • accept the General Terms and Conditions of Rollet Kft.

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In this case a parking and/or charging contract is concluded between the Data Subject and Rollet Kft.

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GTC availability:
https://www.rollet.hu/aszf/westend
https://westend.hu/szabalyzatok

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3.2 Operation of the Parking Application

During the operation of the Parking Application the Data Controller acts as an independent data controller.

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Within this framework the Data Controller:

  • independently determines the purposes of data processing,

  • determines the methods and tools of data processing,

  • ensures the full operation of the “Rollet application” system.

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4. When personal data are processed during use of the Service

4.1 Use without registration

If the user uses the Service without registration, no personal data are recorded.

Users may use the Westend Mobile Application even if they do not create their own user account (“profile”).

In such cases:

  • no personal data are recorded,

  • only basic functions are available.

For example:

  • maps showing the locations of shops

  • navigation within the shopping centre

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4.2 Use with registration

When downloading the Westend Mobile Application, the user may create their own user account (“profile”) by providing personal data.

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In such cases the Data Controller processes personal data related to the Customer Loyalty Programme.

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If the user also registers in the Parking Application, the Data Controller processes additional personal data in order to provide parking and charging services.

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4.2.1 Personal data processed in connection with registration in the Parking Application

Data Subjects: natural persons registering in the Parking Application.

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Registration in the Parking Application qualifies as the conclusion of a contract under the General Terms and Conditions of Rollet Kft.

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Categories of personal data and purposes of processing:

Personal data: e‑mail address
Purpose: execution of parking registration, identification of the data subject, account login verification.

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Personal data: license plate number of the registered vehicle
Purpose: parking registration, entitlement verification, determination of parking fees.

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Personal data: last four digits of bank card and expiration date
Purpose: verification of online payment capability.

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Personal data: entry and exit times of the parking facility
Purpose: determination of parking duration, invoice issuance.

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Personal data: billing name
Purpose: fulfillment of invoicing obligations.

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Personal data: billing address
Purpose: fulfillment of invoicing obligations.

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Personal data: tax number
Purpose: fulfillment of invoicing obligations.

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Personal data: status of online payment transaction
Purpose: confirmation or rejection of transaction processing.

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4.2.2 Legal basis of processing

Legal bases of processing:

  • performance of a contract (GDPR Article 6(1)(b))

  • compliance with legal obligations (GDPR Article 6(1)(c))

Related legislation:

  • Act C of 2000 on Accounting

  • Act CXXVII of 2007 on Value Added Tax

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4.2.3 Duration of data processing

The Data Controller:

  • retains data provided during registration for 5 years following deletion of the registration,

  • retains accounting documents for 8 years.

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4.2.4 Deletion of user account

If the user account in the Westend Mobile Application is deleted, the Parking Application account is automatically deleted as well.

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Data related to parking activity are retained by Rollet for the duration specified in section 4.2.3.

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4.2.5 Data processors acting on behalf of Rollet Kft.

Amazon Web Services Inc.
410 Terry Avenue North
Seattle, WA 98109‑5210
USA

Processed data: all collected data
Tasks: storage of backups, sending automatic emails, storing system events.

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OTP Mobil Kft.
1143 Budapest, Hungária körút 17‑19.

Processed data: bank card data, user name, email address, transaction amount, IP address, transaction time, billing address.
Tasks: processing online payments, transaction authentication, fraud monitoring.

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KBOSS.hu Kft.
1031 Budapest, Záhony utca 7.

Processed data: billing data
Tasks: processing online payments and issuing invoices.

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4.2.6 License plate recognition system processor

Swarco Traffic Hungaria Kft.
1103 Budapest, Gyömrői út 150

Processed data:

  • license plate number

  • entry and exit data

Task:

  • operation of the license plate recognition system.

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5. Place of data storage

Data of the Parking Application are stored on Amazon Web Services (AWS) servers located within the European Union.

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6. Data security measures

The Data Controller:

  • applies information security regulations

  • regulates access rights

  • uses modern IT systems

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Ensured principles:

  • availability

  • authenticity

  • integrity

  • confidentiality

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7. Persons authorized to access the data

The data may be accessed by the Data Controller and its data processors.

In the event of official requests the data may be disclosed to:

  • courts

  • prosecution authorities

  • police

  • Hungarian National Authority for Data Protection and Freedom of Information (NAIH).

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8. Rights of the Data Subject

The Data Subject may request:

  • information about the processing of personal data

  • access to the processed data

  • rectification of personal data

  • deletion of personal data

  • restriction of data processing

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8.6 Deletion of data

Personal data must be deleted if:

  • they are no longer necessary

  • the data subject withdraws consent

  • the processing is unlawful

  • deletion is required by law

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8.7 Legal remedies

Contact with the Data Controller:

Email: support@rollet.hu
Postal address: Rollet Kft., 1046 Budapest, Szabó József u. 6.

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8.7.1 Authority procedure

Hungarian National Authority for Data Protection and Freedom of Information
1055 Budapest, Falk Miksa u. 9‑11.
Telephone: +36 (1) 391‑1400
Email: ugyfelszolgalat@naih.hu
Web: http://naih.hu

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8.7.2 Court procedure

The Data Subject may initiate court proceedings within 30 days of notification of the decision.

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9. Amendment of the Notice

The Data Controller reserves the right to amend this Notice, particularly in the event of:

  • legislative changes

  • recommendations of the NAIH

  • changes in data protection practices.

Data Subjects will be informed in advance of any amendments.

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Rollet Kft.

Data Controller

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