Privacy policy

DATA MANAGEMENT POLICY

 

DATA PROCESSING INFORMATION NOTE

 

CONTROLLER:

Fitness Vision Hungary Limited Liability Company

CONTROLLER’S MAILING ADDRESS:

1082 Budapest, Futó utca 48-50

COMPANY SEAT:

7622 Pécs, Bajcsy-Zsilinszky u. 2/1

BRANCH:

1066 Budapest, Nyugati tér 1-2. (2nd - 3rd floors)

BRANCH:

1082 Budapest, Futó utca 48-50

BRANCH:

1117 Budapest, Október Huszonharmadika u. 8-10

BRANCH:

1134 Budapest, Váci út 35

BRANCH:

1146 Budapest, Hungária krt. 162-166

BRANCH:

1033 Budapest, Flórián tér 6

CONTROLLER’S E-MAIL ADDRESS:

info.corvin@life1.hu; info@gilda-max.hu

CONTROLLER’S TELEPHONE NUMBER:

+36 1 951 1789

 

I.

 

For the sake of transparent data processing, the specific data processing objectives, their legal basis, the categories of data processed, the duration of data processing set out in this present data processing information note are summarised briefly in Part I in a structured and easy to understand way. The objective of processing the data, as well as the legal basis thereof are also indicated in a structured manner in addition to the textual information provided hereinafter.

 

OBJECTIVE OF DATA PROCESSING

LEGAL BASIS FOR DATA PROCESSING

Using sports services – MYLIFE account

Your consent

Direct marketing

Your consent

Electronic monitoring system

Your consent

Providing health, sporting and dietary habits related data to help our company set up the proper workout plan for you

Your consent

 

 

II.

 

In section II of the data processing information note, we provide information on your rights and the specific freedoms you enjoy, the legal remedy options you have regarding the processing of your data, as well as about other important information.


 

I.1. USING SPORTS SERVICES - MYLIFE ACCOUNT

 

I.1.1. WHAT IS THE PURPOSE OF DATA PROCESSING?

In connection with the use of sports services, your identification, checking the right for access to the use of the service and the provision of the user account on the Internet technically necessary for the provision of the services, as well as keeping contact.

 

I.1.2 WHO IS THE CONTROLLER AND WHO IS THE PROCESSOR?

Our company is the controller of your data, we do not employ a data processor.

I.1.3. WHAT IS THE LEGAL BASIS OF DATA PROCESSING?

The registration at our websites, that is at the www.life1.hu or www.gilda-max.com website, or providing a voluntary consent personally at one of the clubs of our Company. [point a) in paragraph (1) of Article 6 of GDPR ]

 

I.1.4 WHAT KIND OF DATA DO YOU PROCESS ABOUT ME?

Your first name and surname name, date of birth, the postal code of your home address, your preferred club, your electronic mailing address or, if you provided it, then your mobile phone number, home and workplace phone numbers.

 

I.1.5 HOW LONG DO YOU PROCESS MY DATA?

Our Company processes your data as long as you maintain your MYLIFE account . Please note, that if you decide on making us delete your personal information, your MYLIFE account will be terminated upon the deletion of your data.

 

I.2. DIRECT MARKETING

I.2.1. WHAT IS THE PURPOSE OF DATA PROCESSING?

To promote the services of our Company and to increase the publicity of the LIFE1 and Gilda Max Fitness clubs operated by our Company.

 

I.2.2 WHO IS THE CONTROLLER AND WHO IS THE PROCESSOR?

Our company is the controller of your data, we do not employ a data processor.

I.2.3. WHAT IS THE LEGAL BASIS OF DATA PROCESSING?

Our Company only processes your electronic mailing address if you have previously, clearly and explicitly provided your consent for our Company to contact you at the electronic mailing address you have provided. [GDPR point a) in paragraph (1) of Article 6 and (1) of Article of Grtv.]

 

I.2.4 WHAT KIND OF DATA DO YOU PROCESS ABOUT ME?

Your name and electronic mailing address. (e-mail address)

 

I.2.5 HOW LONG DO YOU PROCESS MY DATA?

Processing your data for direct marketing purposes starts after you have provided your consent thereto as specified in section no. I.3.3. and lasts until you withdraw your relevant consent.

 

We inform you that you may initiate the withdrawal of your consent without any justification or restriction and at any time at any branch or the headquarters of our company, either personally or by way of a letter sent by post or by way of an e-mail sent to the info@life1.hu or info@gildamax.hu e-mail addresse. Furthermore, you may also withdraw your consent in your personal MYLIFE1 account at any time.

 

I.3. ELECTRONIC MONITORING SYSTEM

I.3.1. WHAT IS THE PURPOSE OF DATA PROCESSING?

The electronic monitoring of our Company’s headquarters and branches (not including locker rooms, washbasins and toilets), processing the images, sounds, and image and sound recordings in order to ensure the protection of human life, health, safety and property.

 

I.3.2 WHO IS THE CONTROLLER AND WHO IS THE PROCESSOR?

Our company is the controller of your data, we do not employ a data processor.

 

I.3.3. WHAT IS THE LEGAL BASIS OF DATA PROCESSING?

Your consent, in the form of implicit conduct.

That is, by way of entering the premises at our Company’s branches or headquarters in which it is displayed in conformity with the law that an electronic monitoring system is installed. [(Sztv. 30§ (2)]

 

I.3.4 WHAT KIND OF DATA DO YOU PROCESS ABOUT ME?

Our Company processes your personal image, voice and conduct.

 

I.3.5 HOW LONG DO YOU PROCESS MY DATA?

For maximum 3 (three) business days as of the recording if the captured image or sound, as well as  image or sound recordings were not used.

 

I.4. HEALTH, DIETARY, SPORTS ACTIVITIES RELATED DATA

I.4.1. WHAT IS THE PURPOSE OF DATA PROCESSING?

Processing data in relation to your health, lifestyle, dietary and sporting habits and the purpose and history thereof, so that our Company may set up the proper workout plan for you.

 

I.4.2 WHO IS THE CONTROLLER AND WHO IS THE PROCESSOR?

Our company is the controller of your data, we do not employ a data processor.

 

I.4.3. WHAT IS THE LEGAL BASIS OF DATA PROCESSING?

Our Company processes your data specified in the following paragraph after you provided your express written consent to processing these data in a separate instrument.   [GDPR point a) in paragraph (1) of Article 6]

I.4.4 WHAT KIND OF DATA DO YOU PROCESS ABOUT ME?

Your state of health, physical condition, any illnesses, furthermore, your dietary and sporting habits.

 

I.4.5 HOW LONG DO YOU PROCESS MY DATA?

Until the achievement of the purpose.

 

 

 

II RIGHTS REGARDING DATA PROCESSING (II. 1 – II. 7) AND LEGAL REMEDY OPTIONS (II. 8)

II.1. RIGHT TO ACCESS

 

You shall have the right to obtain confirmation from our Company as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information.

 

  • The purposes of the processing.
  • The categories of personal data you provided.
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, including in particular recipients in third countries or international organisations.
  • Where appropriate, the envisaged period for which the personal data will be stored, or, if that is not possible, the criteria used to determine that period.
  • The existence of automated decision-making, including profiling, referred to in paragraphs (1) and (4) of Article 22 of GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

 

II.2. RIGHT TO RECTIFICATION

 

You shall have the right to obtain from our Company the rectification of inaccurate personal data concerning you without undue delay upon your relevant request.Taking into account the purposes of the processing, you shall have the right to request incomplete personal data completed, including by means of providing a supplementary statement.

You may also modify incomplete personal data concerning you in your MYLIFE1 account.

 

II.3. RIGHT TO ERASURE

 

You shall have the right to obtain the erasure of personal data concerning you from our Company without undue delay and our Company shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

 

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • You withdraw your consent to processing your personal data for one or more specific purposes or you withdraw your consent to processing your special personal data and there is no other legal ground for the processing of the aforesaid data.
  • Our Company processes your personal data unlawfully.
  • Your personal data have to be erased for compliance with a legal obligation set forth in the Union or Member State law to which our Company is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in paragraph (1) of Article 8 of GDPR.

 

II.4. RIGHT TO RESTRICTION OF PROCESSING

 

You shall have the right to obtain the restriction of processing from the controller where one of the following applies. The restriction shall mean that our Company shall be obligated to continue storing your data but your personal data may only be processed subject to your consent or any law enforcement.

 

  • The accuracy of the personal data is contested by you, in which case the restriction applies for the period enabling our Company to verify the accuracy of your personal data.
  • Processing your data is unlawful and the you oppose the erasure of the data and requests the restriction of their use instead.
  • Our Company no longer needs the personal data for the purposes of the processing, but you require those data for the establishment, exercise or defence of legal claims.
  • You have objected to processing the data pursuant to paragraph (1) of Article 21 of GDPR; in which case the restriction applies for the period while it is verified whether the legitimate grounds of Company override those of yours.

 

II.5. RIGHT TO DATA PORTABILITY

 

You shall have the right to receive the personal data concerning you, which you have provided to our Company, in a structured, commonly used and machine-readable format and have the right to have these data transmitted to another controller without hindrance from our Company, if we process your personal data based on your consent and by automated means.

 

II.6. RIGHT TO OBJECT

 

You shall have the right to object to processing your data for direct marketing purposes at any time. If you object to processing your data for direct marketing purposes, then our Company will not process your personal data for such purposes.

 

II.7. AUTOMATED INDIVIDUAL DECISION-MAKING AND PROFILING RELATED RIGHTS

 

You shall have the right not to be subject to a decision based solely on automated data processing – including profiling – which produces legal effects concerning you or affects you similarly significantly.

This shall not apply if the decision

  • is necessary for entering into, or the performance of, a contract between you and our Company;
  • is authorised by a Union or Member State law to which our Company is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests.
  • is based on your explicit consent.

II.8. LEGAL REMEDY OPTIONS

If, in your opinion, your rights regarding processing your data by our Company are infringed, you have several legal remedy options.

We recommend that you should lodge a complaint at our Company before turning to court or a supervisory authority for legal remedy.

If you do not wish to take this opportunity or intend to enforce a claim against our Company by means of a legal action, then you may turn to the court competent according to your place of residence or stay and claim general compensation or compensation for damage to reputation.

Our Company shall be obligated to pay general compensation for you, if our Company processed your data unlawfully or violated the requirements of data security and the court established the same in a legally binding judgement.

Our Company shall be obligated to pay compensation for damage to reputation [non-material compensation] for you, if our Company infringed your personal rights by means of processing your data unlawfully or violated the requirements of data security and the court established the same in a legally binding judgement.

Enforcing a right at the Authority:

In addition to enforcing a right at court you may also turn to the Hungarian National Authority for Data Protection and Freedom of Information for legal remedy and with your complaints – free of charge.  We inform you that based on the law no one can suffer any disadvantage due to making a report at the Authority.

The contacts of the Hungarian National Authority for Data Protection and Freedom of Information:

 

III OTHER IMPORTANT INFORMATION

III.1. DATA SECURITY

All employees of our Company attaches preferential attention to providing the proper level of protection and security for your personal data. Within the framework of this data security, our objective is to protect your privacy properly, accordingly, we implement procedures which ensure the integrity, security of and exclude any unauthorised access to your personal data.

III.2. WE INFORM YOU THAT WE PROCESS OR CAN PROCESS YOUR PERSONAL DATA IN CONFORMITY WITH THE FOLLOWING LEGAL REGULATIONS

  • 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)
  • Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities (Grtv.)
  • Act CXXXIII of 2005 on  Security Services and the Activities of Private Investigators (Sztv.)

 

We inform you that we regularly supervise our information note in order to ensure the lawfulness of our data processing activities at all times. If we consider that the modification of the information note is required then we will modify it. We will inform you about the said modifications on our website or through the documentation placed in our clubs.

 

27 June 2018