DATA PROCESSING AND STORAGE POLICY FOR PARTICIPANTS

 

1. Purpose of the policy

The purpose of this policy is to provide information about the data processing activities carried out by Balogh Emese Viktória, sole proprietor (hereinafter: the Data Controller), including their purpose, legal basis, duration, the rights of data subjects, and the data security measures, pursuant to the provisions of EU Regulation 2016/679, the General Data Protection Regulation (GDPR), and Hungarian Act CXII of 2011 (the Information Act).

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2. Details of the data controller

• Name: Balogh Emese Viktória, sole proprietor
• Registered seat and mailing address: 2120 Dunakeszi, Barátság útja 37. 9/57.
• Tax number: 90048704-1-33
• Registration number: 59182890
• Phone number: +36 30 799 4612
• E-mail address: viki@legzogyakorlatok.com
• Website: www.legzogyakorlatok.com
  

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3. Purpose of the data processing

The purpose of the data processing, within the framework of the breathing consultation, breathing training, and other events services, is:

• identification and registration of participants,
• establishing and maintaining contact,
• assessment and preparation of personalized breathing exercises,
• conducting the consultations and trainings,
• documenting the service and ensuring its quality,
• fulfilling statutory obligations (e.g. invoicing).

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4. Scope of data processed

The Data Controller processes the following data:

• Name,
• Date of birth, age,
• E-mail address,
• Billing address,
• Phone number (optional),
• Health data (e.g. breathing habits, sleep quality, any illnesses, medication use, related complaints),
  
  
• Photos sent by e-mail (these are not saved or forwarded; they are used solely to design the personalized exercise program and to determine whether referral to another specialist is necessary)

No automated decision-making or profiling takes place.

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5. Legal basis of the data processing

The legal basis of the data processing is:

• GDPR Article 6(1)(a): the consent of the data subject,
• GDPR Article 9(2)(a): the explicit consent of the data subject to the processing of special categories of data (health data),
• Section 5(1) of the Information Act: voluntary consent.

Consent is given by booking an appointment in the scheduling calendar or, in the case of registration by e-mail, by expressing the intention to register.

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6. Data storage and data security

• The Data Controller is solely Balogh Emese Viktória, sole proprietor, who is authorized to process and access the data.
• The data are stored on Google Drive cloud storage, protected by a password and two-factor authentication.
• The data are not downloaded or stored on any local device.
• Video recordings of the consultations and trainings are available for 2 months on the Google Drive cloud platform, after which they are deleted. 
• Photos sent by e-mail are not saved; they are needed solely for designing the personalized exercise program and for recommending further specialists.
• In order to safeguard the security of the data, the Data Controller takes all technical and organizational measures required under Article 32 of the GDPR, including:
  
  • password-protected access,
  • two-factor authentication,
  • virus protection,
  • regular device maintenance.

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7. Data transfer

The processed data are not transferred to any third party in any form, except where required by law (e.g. invoice data to the tax authority).

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8. Data retention period

The data are stored until withdrawn, i.e. until the data subject withdraws their consent. An exception to this are the Zoom video recordings, which are stored on Google Drive for a period of 2 months and are deleted thereafter. 

At the data subject’s request, the data will be deleted within 5 working days.

Such a request may be submitted using the following contact details:

E-mail: viki@legzogyakorlatok.com
Postal address: 2120 Dunakeszi, Barátság útja 37. 9/57.
Phone: +36 30 799 4612

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9. Rights of the data subject

The data subject is entitled to:

• request information about the data processing,
• request rectification of the data,
• request erasure of the data,
• request restriction of the data processing,
• object to the data processing.

These rights may be exercised via the following contact details:

E-mail: viki@legzogyakorlatok.com
Postal address: 2120 Dunakeszi, Barátság útja 37. 9/57.
Phone: +36 30 799 4612

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10. Right to lodge a complaint

In the event of an infringement of their rights, the data subject may lodge a complaint with the National Authority for Data Protection and Freedom of Information (NAIH):

• Address: 1055 Budapest, Falk Miksa utca 9-11.
• Postal address: 1363 Budapest, Pf. 9.
• Phone: +36 1 391 1400
• E-mail: ugyfelszolgalat@naih.hu
• Website: www.naih.hu
  

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11. Closing provisions

This data processing and storage policy is effective as of 12 January 2025, and remains valid until withdrawn or amended.

The Data Controller reserves the right to amend this policy, and will inform data subjects thereof by e-mail or via the www.legzogyakorlatok.com website.