Name of the data controller:\u00a0FitPuli Limited Liability Company<\/b> 2.1.<\/strong>\u00a0For FitPuli Ltd (FitPuli, the Service Provider or the Data Controller), it is of utmost importance to protect the personal data of the visitors of\u00a0www.fitpuli.hu<\/a>\u00a0or\u00a0www.fitpuli.com<\/a>\u00a0and the users of the Fitpuli app.<\/p>\n 2.2.<\/strong>\u00a0FitPuli is committed to process the personal data of the visitors and customers in accordance with applicable laws. FitPuli aims to support the secure browsing of visitors to a maximum extent. FitPuli maintains the confidentiality of its visitors\u2019 and customers\u2019 personal data and processes such data for the success of its business, to exercise its rights and to perform its obligations in relation to it, in accordance with applicable laws. FitPuli only processes personal data that is necessary for the above purpose. FitPuli ensures that the processed data is accurate, complete and up to date.<\/p>\n 2.3.<\/strong>\u00a0At the same time, FitPuli ensures the security of data. In particular, FitPuli implements protection against the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data stored or otherwise processed, as well as sufficient technical and organizational measures and processes that are necessary for compliance with the applicable laws and guidelines. In addition, FitPuli implements internal policies and processes as required under the relevant laws and industry guidelines.<\/p>\n 2.4.<\/strong>\u00a0FitPuli provides its services through the FitPuli website and app. For the performance of its services, FitPuli processes personal data provided by its customers and other data subjects.<\/p>\n 2.5.<\/strong>\u00a0Certain personal data provided is also considered as health data. The relevant laws guarantee enhanced protection in respect of health data. The Data Controller reserves the right to amend this Privacy Statement unilaterally from time to time. Customers and users will be informed of the changes in due course.<\/p>\n 2.6.<\/strong>\u00a0This Privacy Statement sets out the principles of our policies on data processing and of our day-to-day practices as to how we request data from our visitors and customers.<\/p>\n 2.7.<\/strong>\u00a0In this Privacy Statement, we also set out the purposes and the means of such data as well as the way how such data is maintained and secured.<\/p>\n 2.8.<\/strong>\u00a0When preparing this Statement, we considered the applicable laws and the most important international guidelines, in particular, the following:<\/p>\n 2.9.<\/strong>\u00a0Upon the request of our visitors and customers, we will provide detailed information regarding the scope of personal data that we process, the purpose, legal basis and term of data processing as well as any activity relating to data processing.<\/p>\n 2.10.\u00a0<\/strong>In respect of any change in the principles or in its practices relating to data processing, FitPuli undertakes that it will inform the visitors of\u00a0www.fitpuli.hu<\/a>\u00a0or\u00a0www.fitpuli.com<\/a>\u00a0and the users of the FitPuli app at least 8 days in advance so that they are aware of the data processing principles and practices relating to\u00a0www.fitpuli.hu<\/a>\u00a0or\u00a0www.fitpuli.com<\/a>\u00a0at all times.<\/p>\n 2.11.\u00a0<\/strong>FitPuli undertakes that this Privacy Statement reflects the principles and practice it applies to the processing and protection of personal data.<\/p>\n 3.1.<\/strong>\u00a0\u2018controller\u2019<\/strong>\u00a0means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;<\/p>\n 3.2.<\/strong>\u00a0\u2018processing\u2019<\/strong>\u00a0means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;<\/p>\n 3.3.<\/strong>\u00a0\u2018data transfer\u2019<\/strong>\u00a0means making available personal data to a specific third party;<\/p>\n 3.4.<\/strong>\u00a0\u2018cross-border processing\u2019<\/strong>\u00a0means either:<\/p>\n (a) processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or<\/p>\n (b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union, but which substantially affects or is likely to substantially affect data subjects in more than one Member State;<\/p>\n 3.5.<\/strong>\u00a0\u2018deletion of data\u2019<\/strong>\u00a0means rendering data intelligible in such a manner that it is not possible to recover it;<\/p>\n 3.6.<\/strong>\u00a0\u2018specification of data\u2019<\/strong>\u00a0means using an identifier for the data in order to distinguish it;<\/p>\n 3.7.<\/strong>\u00a0\u2018restriction of processing\u2019<\/strong>\u00a0means the marking of stored personal data with the aim of limiting their processing in the future;<\/p>\n 3.8.<\/strong>\u00a0\u2018erasure of data\u2019<\/strong>\u00a0means the complete physical destruction of a carrier of data;<\/p>\n 3.9.<\/strong>\u00a0\u2018processing data on behalf of the controller\u2019<\/strong>\u00a0means performing technical activities relating to data processing, irrespective of the method and means used as well as of the place of processing, provided that the technical activities are carried out with respect of data;<\/p>\n 3.10.\u00a0<\/strong>\u2018processor\u2019<\/strong>\u00a0means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;<\/p>\n 3.11.\u00a0<\/strong>\u2018personal data breach\u2019<\/strong>\u00a0means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;<\/p>\n 3.12.\u00a0<\/strong>\u2018pseudonymisation\u2019<\/strong>\u00a0means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;<\/p>\n 3.13.\u00a0<\/strong>\u2018anonymization\u2019<\/strong>\u00a0means a technical process that ensures that it is no longer possible to recover the connection between the data subject and the relevant data and that the data is deprived of its personal nature;<\/p>\n 3.14.\u00a0<\/strong>\u2018biometric data\u2019<\/strong>\u00a0means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;<\/p>\n 3.15.\u00a0<\/strong>\u2018cookie\u2019<\/strong>\u00a0means a (simple text) file placed on the hard drive of the user through his browser and which makes the user clearly identifiable upon its next visit;<\/p>\n 3.16.\u00a0<\/strong>\u2018recipient\u2019<\/strong>\u00a0means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not;<\/p>\n 3.17.\u00a0<\/strong>\u2018direct marketing activity\u2019<\/strong>\u00a0means all activities, including activities which result in providing information via direct contact and any relating services the purpose of which is to offer goods or services to the data subject, to forward advertisements or to provide information to commercial partners or to consumers in order to advance a deal (purchase);<\/p>\n 3.18.\u00a0<\/strong>\u2018data concerning health\u2019<\/strong>\u00a0means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;<\/p>\n 3.19.\u00a0<\/strong>\u2018data subject\/customer\/consumer\u2019<\/strong>\u00a0means an identifiable natural person who can be identified, directly or indirectly, in particular by reference to the personal data;<\/p>\n 3.20.\u00a0<\/strong>\u2018genetic data\u2019<\/strong>\u00a0means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;<\/p>\n 3.21.\u00a0<\/strong>\u2018third party\u2019<\/strong>\u00a0means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;<\/p>\n 3.22.\u00a0<\/strong>\u2018third country\u2019<\/strong>\u00a0means any country that is not a member state of the European Economic Area;<\/p>\n 3.23.\u00a0<\/strong>\u2018consent\u2019<\/strong>\u00a0of the data subject means any freely given, specific, informed and unambiguous indication of the data subject\u2019s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;<\/p>\n 3.24.\u00a0<\/strong>\u2018publish\u2019<\/strong>\u00a0means making personal data available for everyone;<\/p>\n 3.25.\u00a0<\/strong>\u2018IP address\u2019<\/strong>\u00a0means a unique string of numbers separated by full stops that identifies each computer using the Internet Protocol to communicate over a network;<\/p>\n 3.26.\u00a0<\/strong>\u2018special categories of personal data\u2019<\/strong>\u00a0means data<\/p>\n (a) revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and data concerning a natural person\u2019s sex life or sexual orientation;<\/p>\n (b) data concerning health or addictions, and criminal data;<\/p>\n 3.27.\u00a0<\/strong>\u2018Hungarian Data Protection Authority (DPA)\u2019<\/strong>\u00a0means the data protection authority whose legal status and competencies are governed by section 38 of the Data Protection Act;<\/p>\n 3.28.\u00a0<\/strong>\u2018filing system\u2019<\/strong>\u00a0means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;<\/p>\n 3.29.\u00a0<\/strong>\u2018profiling\u2019<\/strong>\u00a0means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person\u2019s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;<\/p>\n 3.30.\u00a0<\/strong>\u2018personal data\u2019<\/strong>\u00a0means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;<\/p>\n 3.31.\u00a0<\/strong>\u2018identification data\u2019<\/strong>\u00a0means the individual\u2019s first and last name, name at the date of birth, date and place of birth and mother\u2019s name;<\/p>\n 3.32.\u00a0<\/strong>\u2018objection\u2019<\/strong>\u00a0means the data subject\u2019s request in which he objects to the processing of his data and requests that the controller stops processing or deletes his personal data;<\/p>\n 3.33.\u00a0<\/strong>\u2018Robinson list\u2019<\/strong>\u00a0means the registry of data regarding those data subjects who prohibited or \u2013 notwithstanding the initial request of the entity carrying out direct marketing activities \u2013 did not consent to the processing of their personal data for the purposes of direct marketing;<\/p>\n 3.34.\u00a0<\/strong>\u2018customer target list\u2019<\/strong>\u00a0a list containing solely the customer\u2019s name, address, gender, data and place of birth, his interest and marital status and used for communication and advertising purposes;<\/p>\n 3.35.\u00a0<\/strong>\u2018enterprise\u2019<\/strong>\u00a0means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in economic activity.<\/p>\n 4.1.<\/strong>\u00a0This Privacy Statement enters into effect as of 31 January 2018 and remains valid until its withdrawal.<\/p>\n 4.2.<\/strong>\u00a0The GDPR requires that personal data must be processed lawfully and fairly, and the processing must be transparent for the data subject. Accordingly, FitPuli requests the data subjects\u2019 data only for explicit and legitimate purposes and aims to inform the data subjects about the processing of their data in a transparent manner by way of this Privacy Statement. (\u2018Lawfulness, fairness and transparency\u2019)<\/p>\n 4.3.<\/strong>\u00a0Personal data must be collected for specific, explicit and legitimate purposes; the data collected must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. The use of personal data must be restricted to the purpose for which the data has been provided. (\u2018Purpose limitation\u2019)<\/p>\n 4.4.<\/strong>\u00a0The scope of personal data must not exceed what is necessary for the purpose of data processing. This means that FitPuli processes personal data only to the extent it is necessary for its operations. FitPuli aims to request only that personal data that is necessary for the relevant purpose and reviews the scope of data annually, in accordance with the \u2018privacy by design\u2019 principle. (\u2018Data economy\u2019)<\/p>\n 4.5.<\/strong>\u00a0FitPuli keeps the data accurate and, where necessary, up to date and takes every reasonable step to ensure that any inaccurate personal data is erased or rectified. FitPuli aims to call the attention of the data subjects by all means that they may request the rectification of their data. Suh right is also set out in the general terms and conditions. (\u2018Accuracy\u2019)<\/p>\n 4.6.<\/strong>\u00a0During the storing of data, FitPuli aims to keep data for a sufficient period of time, as accurate and up to date data can help its business operations, and its compliance. FitPuli determines and reviews (if necessary) the applicable data retention periods with utmost care. (\u2018Storage limitation\u2019)<\/p>\n 4.7.<\/strong>\u00a0Fituli processes personal data in a manner so that it can ensure the appropriate security of personal data. FitPuli monitors the data security compliance of the Company by way of a monitoring system. (\u2018Integrity and confidentiality\u2019)<\/p>\n 4.8.<\/strong>\u00a0FitPuli aims to demonstrate its data protection compliance (e.g. by way of implementing a Privacy Statement and regular trainings for employees).<\/p>\n 5.1.<\/strong>\u00a0While browsing\u00a0www.fitpuli.hu<\/a>\u00a0or\u00a0www.fitpuli.com<\/a>, our visitors can use the site without revealing their identity or providing any personal data.<\/p>\n 5.2.<\/strong>\u00a0However, in certain cases, our visitors must provide and submit their personal data so that they can use the FitPuli services to a maximum extent.<\/p>\n 5.3.<\/strong>\u00a0Personal identification data means those data or information relating to individuals that make it possible to identify somebody, to contact somebody or to identify its physical contact details \u2013 including but not limited to the following: name, address, postal address, phone number, fax number, email.<\/p>\n 5.4.<\/strong>\u00a0Anonymous data is collected in a way that does not identify any person and does not relate to any person and as a result, no connection can be established with anybody is not considered as personal data.<\/p>\n 5.5.<\/strong>\u00a0Data provided by a third party means the personal identification data \u2013 provided on the basis of necessary consent \u2013 which relates to the person using the service (or a visitor) but which is collected by the service provider by way of a third party, in accordance with applicable laws.<\/p>\n 5.6.<\/strong>\u00a0As a general principle, we declare that when we request personal data from our visitors, they can decide freely after having read the relevant information on our data processing whether they decide to provide the requested data or not.<\/p>\n 5.7.<\/strong>\u00a0Please note that if somebody does not provide his\/her data, in certain cases he\/she may not be able to use the service.<\/p>\n 5.8.<\/strong>\u00a0FitPuli also collects special categories of data that relates to health or addictions.<\/p>\n 5.9.<\/strong>\u00a0This Privacy Statement relates to the data expressly provided to FitPuli and not to data which is made publicly available. If somebody decides to make any of his or her data publicly available, this Privacy Statement does not apply to such data.<\/p>\n 5.10.<\/strong>\u00a0We do not add any further data to or connect data from other sources to the data provided by our visitors.<\/p>\n 5.11.\u00a0<\/strong>We never share the data of our visitors with third parties unless there is a legal basis to do so, or only in anonym form.<\/p>\n If a competent authority requests the service provider to hand over data in accordance with applicable laws (in the case of the suspicion of a crime, and by way of an official request), to comply with its legal obligations FitPuli will hand over the data requested to the extent it is available.<\/p>\n 5.12.\u00a0<\/strong>If our visitors provide personal data to us, we will take all necessary steps to secure such data in the course of network communications (i.e. during online data processing) as well as during the storage of data (i.e. during offline data processing).<\/p>\n 5.13.\u00a0<\/strong>Our obligations to preserve and secure data within the FitPuli infrastructure are specified by specific principles, processes and security controls. All FitPuli personnel is responsible for compliance with such measures.<\/p>\n Only those personnel in relevant positions may have access to personal data \u2013 subject to high-level access control.<\/p>\n 5.14.\u00a0<\/strong>5.14. Should you have any questions in relation to our security measures, please send an email to the Data Protection Officer of the company, Mr. J\u00f3zsef Ol\u00e1h, to it@fitpuli.com.<\/p>\n As a rule of thumb, the legal basis of data processing relating to the provision of the FitPuli service is the informed and voluntary consent of the data subject or on the conclusion of the contract.<\/p>\n In certain cases, the processing, storing and transfer of data is required by applicable laws.<\/p>\n 6.1. Server logs on\u00a0www.fitpuli.hu<\/a>;\u00a0www.fitpuli.com<\/a>;\u00a0www.fitpuli.de<\/a>\u00a0\u00e9s\u00a0www.fitpuli.at<\/a>\u00a0(referred to as www.fitpuli.com)<\/strong><\/p>\n While browsing at\u00a0www.fitpuli.com<\/a>, the server may automatically log the activities of the user.<\/p>\n Purpose of data processing:<\/strong>\u00a0to monitor the operations of the service, to personalize services and to prevent abuse, the Service Provider collects visitor data while browsing the website.<\/p>\n Legal basis:<\/strong>\u00a0the data subject\u2019s consent, and section 13\/A. \u00a7 (3) of Act CVII of 2011 on data processing.<\/p>\n Scope of personal data:<\/strong>\u00a0date, time, IP address, browser data, data of the visited webpage.<\/p>\n Data retention period:<\/strong>\u00a030 days from the date of visiting the webpage.<\/p>\n FitPuli does not connect log data to other information and does not intend to identify its visitors.<\/p>\n The IP address is a unique string of numbers separated by full stops that identifies each computer using the Internet Protocol to communicate over a network. By way of an IP address, the geographic location of the visitor using the relevant computer may be identified. The address of the webpages visited, the date and time alone cannot identify the visitor. However, together with other data (e.g. the data provided upon registration), the IP address may make it possible to draw conclusions regarding the user.<\/p>\n
\nShort name:\u00a0FitPuli Ltd.<\/b>
\nRegistered seat:\u00a0Kat\u00f3d Street 6. I\/3., Gy\u0151r, H-9024, Hungary<\/b>
\nRepresentative:\u00a0Dr D\u00e1niel Ol\u00e1h, managing director<\/b>
\nData protection registration number:\u00a0NAIH-141195\/2018<\/b>
\nTax number:\u00a026103639-2-08<\/b>
\nCompany registration number:\u00a0Cg. 08-09-029303<\/b>
\nWebpage:\u00a0www.fitpuli.hu<\/b>\u00a0\/\u00a0<\/a>www.fitpuli.com<\/b><\/a>
\nEmail:\u00a0info@fitpuli.com<\/b><\/a>
\nEmail of the DPO:\u00a0it@fitpuli.com<\/b><\/a><\/p>\n2. Introduction<\/h3>\n
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3. Definitions relating to personal data<\/h3>\n
4. Rules of data processing<\/h3>\n
5. Background information regarding the processing of personal data<\/h3>\n
6. Scope, purpose, legal basis and term of data processing<\/h3>\n