Privacy Policy

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Privacy Policy

This policy (hereinafter the “Policy”) governs the processing of any information (personal data) relating to an identified or identifiable natural person (data subject) by trehab physiotherapy (hereinafter “trehab physiotherapy”).

In this document you will find information on what personal data are processed by trehab, with what purpose and on what legal basis, for how long as well as on who may have knowledge of, or access to, the personal data processed by trehab physiotherapy.

In addition, this document also contains detailed information on your rights relating to the data processing and how to exercise them.

If you have any questions or comments relating to the data processing or this Policy, please write us to the following email address: info@trehab.hu.

Trehab physiotherapy may amend this Policy if, among other cases, it introduces a new data processing process or changes an existing process and will inform its clients and other data subjects of an amendment to this Policy primarily on its website.

 

1. General information on the data processing

 

Trehab physiotherapy as data controller processes and protects all information relating to a natural person (e.g., identification data, contact information, data concerning health, etc.), i.e., personal data in accordance with Regulation (EU) 2016/679 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 – GDPR) and the applicable Hungarian laws.

 

Name:

TEAM Rekreáció Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság

H-1024 Budapest, Margit krt. 11. félemelet 1.

Company Registration Number: 01-09-881227

E-mail: info@trehab.hu

Telephone: +36 20 232 9624

Website: www.trehab.hu

 

Data processing includes any operation or set of operations which is performed on personal data, such as recording, storage, consultation, use, disclosure, transmission, erasure or destruction. Trehab physiotherapy processes personal data taking all necessary and suitable measures to prevent unauthorised access to or use of personal data. This includes ensuring the physical protection of its premises (e.g., by operating alarm systems and video surveillance systems) and the protection of its electronic systems against unauthorised access with logical security measures (e.g., by using a firewall and secure authentication).

Access to the personal data processed by trehab physiotherapy may be granted to its employees and collaborators to the extent necessary for completing their tasks and for providing you services, subject to confidentiality commitment. In addition, trehab physiotherapy may transfer the personal data it processes to third parties, e.g., to authorities in order to comply with a requirement of the law. Your personal data may be transferred in order to provide you services (e.g., when using a third party service provider) or if trehab physiotherapy engages a third party, i.e., a data processor acting on its behalf, and in accordance with its instructions, for certain data processing operations (e.g., storage, organisation). In case of the data processing described above, trehab physiotherapy ensures that personal data is transferred only to data processors that ensures the protection of your personal data by applying adequate security protocols.

Trehab physiotherapy reserves the right to amend this Policy unilaterally with effect from the date of the amendment. Therefore, if you have any questions regarding our data processing or the protection of personal data, we recommend that you visit the website of trehab physiotherapy and consult the latest effective version of the Policy.

 

2. Data Processed by trehab physiotherapy

 

This section contains general information regarding the various data processing activities for different purposes by trehab physiotherapy. If you require personalised information, e.g., to whom and when did trehab physiotherapy transferred your personal data, please send a request via email to info@trehab.hu.

Data Processing Related to the Provision of Healthcare Services and Performing Healthcare Services Agreements

 

Purpose of Data Processing

Provision of healthcare services, entering into, amendment or termination of, an agreement for providing healthcare services, performance of obligations under such agreements, exercise of rights and exercise or defence of potential legal claims and purposes of contact.

 

Legal Basis of Data Processing 

Performance of a healthcare contract (GDPR Article 6(1)(b))

Compliance with a legal obligation (GDPR Article 6(1)(c)), legitimate interest of trehab physiotherapy to exercise legal claims (GDPR Article 6(1)(f))

 

Personal Data Being Processed

Trehab physiotherapy processes the following data:

– identification information (e.g., name, date of birth, mother’s maiden name),

– contact information (address, mailing address, phone number, email address),

– data concerning health produced in relation to the provision of healthcare services, social security number (TAJ),

– in case of a person insured by a health insurance service provider under a group health insurance coverage: employer, health insurance package

– scope of work, religious beliefs, racial or ethnic origin, if this information is relevant to providing healthcare services.

 

The above personal data is provided to trehab physiotherapy either by you in relation to the healthcare services or by another healthcare service provider, subject to your consent. In addition, in case of occupational health services, your employer, acting as our client, transfers us your identification and contact information necessary for the occupational health examination. If you are insured by a health insurance service provider, the insurance service provider transfer us your identification and contact information necessary for providing healthcare services.

 

What constitutes data concerning health?

Data concerning health includes all data pertaining to the physical or mental health status of a natural person and any data concerning the natural person’s health status produced in relation to a healthcare service provided to him/her.

 

Duration of Data Processing and Deletion

In accordance with Act XLVII of 1997 on the Processing and Protection of Personal Data Concerning Health and Related Personal Data, trehab physiotherapy processes and retains all personal data concerning health and identification information related to the healthcare services and included in the healthcare documentation for a period of 30 years and all discharge summaries for a period of 50 years. Trehab physiotherapy processes and retains diagnostic imaging results for a period of 10 years after the date of producing the images. Following the expiry of the above terms, the relevant healthcare documentation will be erased and destroyed.

 

Categories of Recipients, Transfer of Data

Trehab physiotherapy transfers personal data to the following recipients:

– to its healthcare service provider partners: data required for the purpose of providing healthcare services and treatment and the performance of the agreement, (e.g., in order to conduct laboratory tests, providing emergency care, providing certain special health services);

– to authorities defined in the law in order to comply with reporting obligations (e.g., compliance with obligations to provide data to the EESZT system via the HEALZZ2 system;

– to authorities and courts of law defined in applicable acts of law, if officially requested by such authorities or courts and in accordance with applicable law;

– to its data processor providing document archiving and document storage services, in accordance with the relevant data processing agreement;

– to its data processor providing server hosting services, in accordance with the relevant data processing agreement;

– to delivery companies acting as data processors: the data required for delivery (name and address), in accordance with the relevant data processing agreement.

 

Consequences of Failure to Provide Data 

Data is required for the provision of healthcare services and the performance of the related agreement, therefore, if the required data is not provided, the services may not be provided or may not be provided appropriately.

 

Data Processing Related to Complaints

 

Purpose of Data Processing

Processing complaints, investigating the circumstances of cases regarding which a complaint was made and resolving complaints.

 

Legal Basis of Data Processing

Performance of contract (GDPR Article 6(1)(b));

Performance of legal obligations relating to the processing complaints under Act CLIV of 1997 on Healthcare (GDPR Article 6(1)(c));

Your consent as the data subject given by filing a complaint to trehab physiotherapy, in particular when the relevant healthcare services were not provided to you but for example to a relative of yours and, nevertheless, you file a complaint (GDPR Article 6(1)(a));

 

Personal Data Being Processed

Identification information of the person filing the complaint included in the filing (typically, name, email address, home address) and the personal data, including data concerning health, contained in the complaint.

 

Duration of Data Processing and Deletion

In accordance with Section 29(4) of Act CLVI of 1997 on Healthcare, trehab physiotherapy processes the data for a period of 5 years following the completion of the complaint process, after which period the data will be erased and destroyed.

 

Categories of Recipients, Transfer of Data

Trehab physiotherapy transfers personal data related to complaints, including data concerning health, to the following recipients:

to its healthcare service provider partners, in order to allow investigation of the healthcare service regarding which the complaint was made;

– to authorities and courts of law defined in applicable acts of law, if officially requested by such authorities or courts and in accordance with applicable law;

– to its data processor providing document archiving and document storage services, in accordance with the relevant data processing agreement;

– to delivery companies acting as data processors: the data required for delivery (name and address), in accordance with the relevant data processing agreement;

– in case of a person insured by a health insurance service provider: to the insurance service provider or to the employer, provided that the complaint was received via either of them and the data subject consented to such transfer of personal data to the insurance service provider or the employer in relation to the handling of the complaint.

 

Consequences of Failure to Provide Data

All relevant information related to the complaint is necessary for the processing of a complaint and for examining all circumstance of the complaints. If the data is not provided or not provided in full, the complaint may not be resolved or may not be adequately resolved.

 

Recording Telephone Conversations

 

Purpose of Data Processing

The general purpose of recording telephone conversations is to evidence what was said during the telephone conversation. The purpose data processing related to complaints via telephone is to accurately record and register complaints. In addition, data is processed for the purpose of providing services, responding appropriately to inquiries made via telephone and ensuring constant improvement of the quality of trehab physiotherapy’s services.

 

Legal Basis of Data Processing

The legal basis for the data processing is your consent as the data subject given by continuing the phone call following the notification regarding the recording of the telephone call (GDPR Article 6(1)(a));

In addition, data is processed on the basis of the legitimate interest of trehab physiotherapy in having quality assurance and exercising legal claims (GDPR Article 6(1)(f)).

 

Personal Data Being Processed

The data subject’s voice and the personal data shared during the phone call placed to +36 20 232 9624, the time and duration of the phone call and the phone number.

 

Duration of Data Processing and Deletion

The duration of the data processing coincides with the statutory limitation period (deadline for filing claims: 5 years following the end of the phone call or, in case of complaints, the completion of the complaint process), after which period the data will be erased and destroyed.

 

Categories of Recipients, Transfer of Data

Trehab physiotherapy transfers personal data provided during phone calls to the following recipients: – to authorities and courts of law defined in applicable acts of law, if officially requested by such authorities or courts and in accordance with applicable law;

 

Consequences of Failure to Provide Data

In case of complaints made via telephone, if the data is not provided or not provided in full, the complaint may not be resolved or may not be adequately resolved. In other cases, in the absence of providing personal data, the request of the data subject may not be fulfilled and queries regarding the data subject may not be provided.

 

Data Processing Related to Other Inquiries, Client Satisfaction Questionnaires and Maintaining Contact

 

Purpose of Data Processing

The purpose of the data processing is maintaining contact, performance of a contract entered into with trehab physiotherapy, if applicable, the provision of services, collecting and evaluating feedback regarding the quality of services and thereby increasing the quality of services. In other cases, the purpose of the data processing is to respond to notifications, inquiries or questions.

 

Legal Basis of Data Processing

In relation to the contact persons indicated in the agreements with the partners of trehab physiotherapy, the legitimate interest of trehab physiotherapy and its contracting partner to perform the agreement (GDPR Article 6(1)(f)).

In the case of other notifications, inquiries, questions or the completion of customer satisfaction questionnaires your consent as the data subject given to trehab physiotherapy by submitting a request or completing and signing a survey to trehab physiotherapy (GDPR Article 6(1)(a));

 

Personal Data Being Processed

The following data of the person indicated as the contact person in the agreement, as well as the person that contacts trehab physiotherapy directly or via the WEBSITE handled by the data processor of trehab physiotherapy with a notification, an inquiry or a question:

– name,

– (work) phone number,

– (work) email address,

– other personal data included in the inquiry, notification, client satisfaction questionnaire;

 

Duration of Data Processing and Deletion

In case of the personal data of contact persons specified in an agreement, data is processed durint the term of the relevant agreement and for a period equal to the limitation period defined in the statute of limitation (claims may be filed within 5 years). In other cases, the duration of the data processing is a period of 5 years (statute of limitation) after the receipt of the inquiry, after which period the data will be erased and destroyed.

 

Categories of Recipients, Transfer of Data

Trehab physiotherapy transfers personal data to the following recipients:

– to authorities and courts of law defined in applicable acts of law, if officially requested by such authorities or courts and in accordance with applicable law;

– to its data processor providing document archiving and document storage services, in accordance with the relevant data processing agreement;

The creator and the editor of the relevant website have access as data processors of trehab physiotherapy to the data provided via the websites operated by trehab physiotherapy.

 

Consequences of Failure to Provide Data

It is not possible to maintain contact without the data of the contact person.

 

Processing of Data of Job Applicants and Data Processing Related to Recruitment Databases

 

Purpose of Data Processing

Fulfilling employment vacancies, compiling company recruitment database.

 

Legal Basis of Data Processing

The legal basis for the data processing is your consent as the data subject given by your submission of your application to trehab physiotherapy (GDPR Article 6(1)(a)); In addition, data is processed on the basis of the legitimate interest of trehab physiotherapy in filling positions (GDPR Article 6(1)(f)).

 

Personal Data Being Processed

In case of applicants, data received directly from the applicant or via a job portal:

– name;

– contact information (phone number, email address);

– any other personal data provided by the applicant in his/her resumé in relation to the application;

in case of persons included in the recruitment database of trehab physiotherapy:

– name;

– any other personal data of the data subject shared by him/her on social media platforms and job portals (e.g., information on education, work experience).

 

Duration of Data Processing and Deletion

In case of an unsuccessful application, a period of 2 years following the submission of the application, in case of persons included in the recruitment database, a period of 2 years following the inclusion of the data in the recruitment database of trehab physiotherapy. Following the expiry of the above terms, the data will be erased and destroyed.

 

Categories of Recipients, Transfer of Data

Trehab physiotherapy may only transfer the personal data of the applicants to the management of trehab physiotherapy.

 

Consequences of Failure to Provide Data

In case of applicants, if the data is not provided in full, the application may not be successfully evaluated.

 

Newletters, direct marketing

 

Purpose of Data Processing

Direct marketing, promotion of the services of trehab physiotherapy, facilitating the use of its services.

 

Legal Basis of Data Processing

Your consent as the data subject and the legitimate interest of trehab physiotherapy to do conduct direct marketing.

 

Personal Data Being Processed

The following data provided by you as the data subject:

– name

– email address

– IP address

– Date of subscription

 

Duration of Data Processing and Deletion

Trehab physiotherapy processes the personal data until objection against the data processing or the withdrawal of consent.

 

Categories of Recipients, Transfer of Data

Trehab physiotherapy transfers the personal data exclusively to authorities and courts of law defined in applicable acts of law, if officially requested by such authorities or courts and in accordance with applicable law.

 

Consequences of Failure to Provide Data

If the data is not provided, the provision of newsletter services becomes impossible.

 

Data Processing Related to the Electronic Security System

 

Purpose of Data Processing

For security purposes, trehab physiotherapy operates a video surveillance system at its premises at H-1024 Budapest, Margit krt. 11. félemelet 1., in the waiting area and the corridors. No video cameras have been installed in the examination rooms and the doctors’ offices.

 

Legal Basis of Data Processing

The legal basis of the data processing is the consent given by the data subject by entering into the rooms equipped with video cameras and the legitimate interest of trehab physiotherapy in protecting property.

 

Personal Data Being Processed

The personal data processed by trehab physiotherapy is the video recording made of the data subject, the data subject’s conduct recorded on the video and the date and time of the recording.

 

Duration of Data Processing and Deletion

Trehab physiotherapy deletes the video recordings following the expiry of 14 working days after the date of the recording unless it is used in a official or court procedure in accordance with Act CXXXIII of 2005 on personal and property protection and private investigation.

 

Categories of Recipients, Transfer of Data

Trehab physiotherapy transfers the video recordings exclusively to authorities and courts of law defined in applicable acts of law, if officially requested by such authorities or courts and in accordance with applicable law.

 

Consequences of Failure to Provide Data

If the data is not provided, no healthcare services may be provided at the healthcare service location where video cameras have been installed.

 

Video recordings are stored on trehab physiotherapy’s the servers located in locked rooms, applying high level data security protocols. Unauthorised persons may not have access to the recordings, access is given exclusively to the authorised personnel and collaborators of trehab physiotherapy as well as data processors responsible for security services (in accordance with the relevant data processing agreement) and in each case to the extent required to complete their tasks. You, as the data controller, have the right to request that a recording not be destroyed until any inquiry by a court or other authority but not longer than 30 days, provided that it is necessary for exercising your rights or legal interests (e.g., for the investigation of the circumstances of a potential criminal act). You, as the data controller, have the right to request a copy of only those recordings that do not include other persons or other persons may not be recognised on them.

 

Data Processing Related to Social Media Profiles

 

Purpose of Data Processing

Managing and moderating the social media profiles (Facebook) of trehab physiotherapy, promoting the services of trehab physiotherapy and continuous improvement of the services of trehab physiotherapy via analysing traffic data.

 

Legal Basis of Data Processing

The legal basis of the data processing is, on the one hand, your consent as the data subject given by, for example, entering the website, posting an opinion or a comment to the posts of trehab physiotherapy (GDPR Article 6(1)(a)), and, on the other hand, the legitimate interest of trehab physiotherapy in appropriately managing and moderating the social media profiles of trehab physiotherapy (e.g., by deleting offensive comments; GDPR Article 6(1)(f)).

 

Personal Data Being Processed

Name and any other personal data of the data subject provided by him/her on the social media platform in relation to trehab physiotherapy’ profile or included by the data subject in a comment.

 

Duration of Data Processing and Deletion

Personal data (including comments) will be deleted, at the latest, after 5 years (general statute of limitation) following the entry onto the website or the posting of a comment.

 

Categories of Recipients, Transfer of Data

Trehab physiotherapy does not transfer personal data obtained via managing its social media profiles.

 

Consequences of Failure to Provide Data

There are no consequences to a failure to provide personal data.

 

3. Cookie policy

 

What are cookies?

Cookies are small data files, packets of data, that are placed on your device (computer, phone, table) during visiting or browsing on a website.

Cookies serve several purposes. Cookies collect data on the use of the relevant website and its visitors, in most cases in order to enhance user experience and to place targeted ads.

Cookies cannot identify visitors of a website, they can only identify the visitor’s device (computer, telephone, tablet). Cookies cannot run applications or viruses.

Please find our cooky policy here.

 

What kind of cookies does the website operated by trehab physiotherapy use and for what purpose?

Trehab physiotherapy uses cookies on its following websites:

Name and address of website (including subdomains): www.trehab.hu

In relation to the above website, Trehab physiotherapy uses the following third party cookies, i.e., cookies not developed by trehab physiotherapy but by a third party service provider.

Cookie Purpose of the cookie and data collected by the cookie 
Google Adwords cookies These cookies collect data about the visits to the webpages of trehab physiotherapy (e.g., subpages visited). These cookies are used for remarketing purposes, i.e., they facilitate that you receive trehab physiotherapy advertisements while visiting other websites following your visit to trehab physiotherapy’s website.
Google Analytics cookies These cookies collect statistical data on the visits to the websites of trehab physiotherapy in order to allow analyses of the use of, and visits to, the websites (e.g., subpages visited, number of visitors, approximate geolocation of visitors etc.). Trehab physiotherapy uses the statistical data received via the Google Analytics services regarding the traffic on, and use of, its websites to improve its websites.
Facebook cookies These cookies also collect data on the use of the websites of trehab physiotherapy (e.g., subpages visited) so that you may receive targeted trehab physiotherapy advertisements on your Facebook wall.

 

You may find additional information on the above cookies on the following websites:

https://policies.google.com/technologies/types

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage https://www.facebook.com/help/cookies/

 

How long are cookies stored and how to delete them?

The above cookies are loaded onto your browser with your permission, i.e., your consent, given during your visit to the website of trehab physiotherapy. The lifetime of cookies varies, but in any case they are automatically deleted within 2 years after being placed on your browser. You may also delete the cookies from your computer at any time or set your browser to block the use of cookies. The following link provides information on how to delete or block cookies from the most commonly used browsers:

Google Chrome

Firefox

Microsoft Internet Explorer

However, if you block cookies, the website of trehab physiotherapy may not work optimally as it was designed in your browser.

 

4. What are your rights in relation to the personal data processing?

 

You are entitled to:

– obtain information, access to your personal data and a copy of your personal data,

– rectification of your personal data,

– withdraw your consent to the data processing, erasure of your personal data (i.e., ‘right to be forgotten’),

– object to the data processing,

– have the data processing restricted (restriction of processing),

– data portability,

 

  1. Right to obtain information

In addition to the information provided in Section 2, you have the right to request from trehab physiotherapy at the addresses and phone number provided in Section 1, specific information on whether trehab physiotherapy processes your data and if yes, what data, for what purpose, on what legal basis and for how long; in addition you have the right to request information as to how trehab physiotherapy obtained your personal data, whether trehab physiotherapy transferred or gave access to your personal data to any third parties, if yes, the name of such third party, when, with what purpose, and you may also request information regarding your specific rights related to the data processing. Trehab physiotherapy provides the information free of charge, however, in the case of an evidently unfounded or excessive request (including if it is repeated), trehab physiotherapy may request a reasonable fee as the condition precedent to the provision of the information.

You have the right to request a copy your personal data being processed either in an electronic or another (including paper) format, for which trehab physiotherapy may charge a fee proportionate to the related administrative costs, as permitted under the relevant provisions of applicable law.

Trehab physiotherapy shall fulfil your request for information subject to any third party rights (including rights pertaining to business secrets and intellectual property).

 

  1. Right to Rectification

If you discover that any of your data processed by, or stored in the systems of, trehab physiotherapy (e.g., contact information, email address, phone number) is incorrect (e.g., contains a typo) or is incomplete and send a request to any of the addresses and phone number of trehab physiotherapy listed in Section 1, trehab physiotherapy will complete your incomplete personal data or correct your incorrect personal data. In addition, trehab physiotherapy will inform any third parties to which it has transferred your personal data about the rectification, unless providing such information is impossible or would impose unreasonable difficulties on trehab physiotherapy.

 

  1. Withdrawal of Consent; Right to Erasure, Right to be Forgotten

You have the right to withdraw your consent to the data processing at any time, however, without affecting the lawfulness of processing based on consent before its withdrawal.

If you withdraw your consent to the data processing and

– no other legal basis applies to the data processing, or

– if the purpose of the data processing no longer exists, or

– the data processing is unlawful, or

the data must be deleted pursuant to a provision of the law, then trehab physiotherapy will permanently erase your data from its systems or destroy them subject to your request sent to the addresses or phone number provided in Section 1. In addition, trehab physiotherapy will inform any third parties to which it has transferred your personal data about the rectification, unless providing such information is impossible or would impose unreasonable difficulties on trehab physiotherapy.

 

  1. The right to object

If the data processing is based on the legitimate interest of trehab physiotherapy or a third party, you have the right to object to the data processing by contacting us at the addresses and phone number provided in Section 1, in which case trehab physiotherapy will stop processing your personal data, unless compelling legitimate grounds exist for the processing.

 

  1. Right to Restriction of Processing

You have the right to request restriction of the processing of your personal data by contacting us at the addresses and phone number provided in Section 1, in which case trehab physiotherapy will only continue to store your personal data without using them or continuing to process them (e.g., by transferring or erasing them); trehab physiotherapy may only use of process such personal data during the period of restrictions subject to your consent or if using the personal data becomes necessary for the exercise of defence of legal claims, for the defence of third party rights or the important grounds of public interest laid down by Union or Member State law so require. In addition, trehab physiotherapy will inform any third parties to which it has transferred your personal data about the rectification, unless providing such information is impossible or would impose unreasonable difficulties on trehab physiotherapy.

You have the right request resitriction of the data processing if,

– you believe that your data are incorrect and would not like trehab physiotherapy to use them until the data are corrected, or

– you believe the data processing is unlawful, or

– the purpose of the data processing no longer exists, however, you do not wish to have your data erased, e.g., because you continue to need the data for, e.g., establishment, exercise or defence of legal claims.

You have the right to request the restriction of the data processing simultaneously with the objection to a data processing based on the legitimate interest of trehab physiotherapy or a third party, in which case the restriction will continue until the date of the decision regarding the objection at the latest.

 

  1. Data Portability

If the data processing is based on your consent or is necessary for the performance of a contract with you or is carried out by automated means, then you have the right to contact us at the addresses and phone number provided in Section 1 and request to receive only the personal data concerning you, which you provided to trehab physiotherapy, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, provided that in case of health data, your right to data portability is subject to exemption from confidentiality. Trehab physiotherapy shall fulfil your request subject to any third party rights (including rights pertaining to business secrets and intellectual property).

 

5. Exercising Rights in regard to Processing

 

You may send us your request to exercise your rights specified above by contacting us at the addresses and phone number provided in Section 1. Please included at least two different personal data in your request so that trehab physiotherapy can identify you (e.g., name and phone number, name and email address). You may also submit a request or inquiry to us verbally at the phone number provided in Section 1 above, however, trehab physiotherapy will in any event respond to your request or inquiry (primarily via the method you have chosen, or you have not chosen a method, based on the decision of trehab physiotherapy via email or physical mail. If you submit a request to us (via email or in physical form), please indicate the manner in which you would like to receive a response (e.g., electronically via email or regular mail), trehab physiotherapy will send you the response as requested. Trehab physiotherapy will respond to requests and inquiries regarding data processing within 30 days or, as an exception, within 60 days (e.g., due to the complexity of the request). Trehab physiotherapy will inform the applicant of the extension of the deadline and the reasons therefor within 1 month following receipt of the request.

 

I am Underage. How should I proceed?

If you are less than 16 years old, you may exercise your rights described above with the consent of your parent exercising parental rights. If you are over 16 years old and less than 18 years old, you may give your consent to the data processing, however, you may only exercise your rights described above with the consent of your legal representative, i.e., typically your parent exercising parental rights.

 

What Rights May be Exercised regarding Deceased Relatives?

For a period of 5 years following the death of the relevant person the person authorised by the dead person during his/her lifetime in If the data subject did not authorise anyone in his/her lifetime, for a period of 5 years following the death of the data subject a close relative (the close relative, i.e., spouse, lineal decendants and ancestors, adopted-, step- or foster children, the adoptive-, step- or foster parent that takes action first) has the right to exercise the right to rectification or objection or, if the data processing was unlawful already during the lifetime of the data subject or if the data processing purpose no longer exists due to the death of the data subject, the right to erasure and the right to restriction of data processing. Trehab physiotherapy will inform the applicant of the extension of the deadline and the reasons therefor within 30 days following receipt of the request.

 

6. Legal Remedies – Data Protection Officer, supervisory authority, court

 

You may contact our colleague with any questions regarding the data processing, the exercising of the above rights and the responses given by trehab physiotherapy to any request or inquiry relating to data processing at:

Email:  info@trehab.hu

Mailing address: H-1024 Budapest, Margit krt. 11. félemelet 1.

 

You have the right to file a complaint regarding the data processing conducted by trehab physiotherapy to the supervisory authority, i.e. the Hungarian National Authority for Data Protection and Freedom of Information at:

National Authority for Data Protection and Freedom of Information

Seat: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c

Mailing address: H-1530 Budapest, Pf.: 5.

Email: ugyfelszolgalat@naih.hu

Telephone: +36 (1) 391-1400

Website: www.naih.hu

 

In addition, you may also bring court proceedings for exercising your rights and claims relating to the data processing before the court. You may initiate court proceedings before the court that is competent based on your permanent address or temporary residence.

By providing your personal data to us you confirm that you have read and explicitly agree to the version of this Policy in effect at the time of you providing us the data. Special privacy protection conditions may apply when you use certain additional services; you may receive information regarding these special conditions before you start using these services, such as the collection of data and the provision of information during the admission process and during other stages of the medical care procedure.

 

7. Data Processors

 

The Company may engage data processors in order to facilitate the Company’s business, to ensure the continuous and adequate functioning of the Website, to facilitate the IT functioning of the software used by the Data Controller for sending newsletters, by means of technical steps required for the secure running of the software.

 

Data processors used by trehab physiotherapy:

Physiotherapists, therapeutic masseurs

Receptionists

Máté Czakó, managing directors

Employees of TEAM Rekreáció Kft.

 

8. Data Protection Information Played in relation to Recorded Phone Calls

 

“Please note that trehab physiotherapy records your call for quality assurance and data protection purposes. You may listen to our detailed privacy notice by pressing the xxx key or read it in our policy on our website.”

 

Privacy Policy related to the Recording of Phone Calls

Your call with trehab physiotherapy (hereinafter the “Company”) will be recorded in accordance with Sections 17/A(3) and (4) of Act CLV of 1997 on Consumer Protection.

 

Purpose of Data Processing

Registering, investigating and assessment of complaints.

 

Data Processed

Data provided by the client (name, address/mailing address, phone number, email address, other information voluntarily provided by the client in the complaint), unique identification number, audio recording of phone call initiated via customer service call centres (voices of the client, any other data subject no qualifying as a client and the customer service colleague.

 

Legal Basis of Data Processing

Your voluntary consent under GDPR Article 6(1)(a) (given by you continuing the phone call after you have listened to the brief summary of information at the beginning of the phone call), handling clients’ complaints under Section 17/A(2) through (6) of Act CLV of 1997 on Consumer Protection.

 

Data Retention Period

Unless you withdraw your consent, the Company retains the relevant recording as well as the related personal data for a period of 5 years (in accordance with Section 6:22(1) of Act V of 2013 on the Civil Code) with a view to enforcing potential civil law claims by the Company or defending potential civil law claims by the data subject.

The Company is required to retain a copy of the complaint protocol and of the response given to it for a period of 5 years and is required to present it to supervisory authorities, if requested [Fgytv. 17/A. § (7)].

 

You as a client have the following rights in relation to the data processing:

 

The right to obtain information

Under Article 15(1) of the GDPR, you have the right to be provided information regarding the processing of your personal data, rectification of inaccurate personal data and, unless the data processing is required by law, erasure of your personal data in the manner indicated during the collection of data or at the addresses or phone number of the data controller indicated in this document.

In this case the Company will send to the address you indicated (email address, mailing address) the following information:

– what personal data it processes regarding you;

– for what data procession purposes;

– duration of data processing;

– your rights relating to the data processing;

– your right to file a complaint to the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter the “Data Protection Authority).

 

The Right to Obtain a Copy

Under Article 15(3) and (4) of the GDPR you have the right to request a copy of the personal data processed by the Company. In this case the Company will send to the address you indicated (email address, mailing address) your personal data processed by the Company. In accordance with the provisions of the Consumer Protection Act, at your request, the Company will allow you to listen to the audio recording free of charge at the Company’s customer service location within 30 days and makes available a copy of the audio recording one a year per recording. At your request, the Company provides you a copy of the audio recording electronically. You may exercise these rights jointly or separately. The only condition to disclosing the recording is that you are identified by the Company. The Company must inform you of the obligations regarding the recording of the call, the retention and disclosure of the audio recording and the unique identifying number at the beginning of the phone call.

 

Right to Rectification

If you request, we will rectify your personal data accordingly in accordance with Article 16 of the GDPR.

 

Right to Erasure

You have the right to request erasure of your personal data if the purpose for which they were collected according to this Policy have been fulfilled or if the data processing was unlawful.

 

Right to Restriction of Processing

You have the right to request the restriction of data processing in the following cases:

– if you contest the accuracy of the personal data, we will restrict the data processing until the Company verifies the accuracy of the personal data;

– the data processing is unlawful, however you object to the erasure of the data and instead request that the use of the data be restricted;

– the Company no longer needs the personal data but you require them for the establishment, exercise or defence of legal claims;

If you request for the restriction of processing you are required to indicate the reason for the restriction. The Company will fulfil any requests for the restriction of processing by separating and storing the personal data entirely separate from all other personal data. For example, electronic data files will be saved on external data storage devices and paper-based documents will be retained in a separate folder.

 

Common Rules of Exercising Rights

The Company fulfils claims within one month, which period may be extended by up to two months.

If the Company rejects your claim, the Company will notify you within one month following receipt of the request of the reasons for the rejection and of the fact that you may file a complaint before the Data Protection Authority and may appeal decisions before the court.

The Company reserves the right to request the information necessary for identifying the client in the event that the Company has a reasonable doubt about the identity of the data subject. For example, if the data subject exercises its right to request a copy of his/her data being processed, it qualifies as giving rise to reasonable doubt and the Company should be entitled to verify the identity of the data subject.

 

How to Exercise Legal Claims

If you believe that the Company’s data processing activity does not comply with legal requirements, you may initiate a procedure at the Hungarian Authority of Data Protection and Freedom of Information.

Seat: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c

Mailing address: H-1530 Budapest, Pf.: 5.

Email: ugyfelszolgalat@naih.hu

Telephone: +36 (1) 391-1400

Website: www.naih.hu

 

You are also entitled to initiate legal proceedings against the Company at the competent court. You are entitled to file a claim before the competent county court of your permanent address or your place of residence, at your convenience.

 

Budapest, February 2, 2021

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