PRIVACY POLICY

IV. Special Principles for Processing Personal Data at HKF Centrum

1.What personal data will be needed and for what purpose? (Purpose of processing the personal data of Users)

• Name, surname, phone number, and email address, as well as the name and surname of the person for whom the service will be provided, and their date of birth – for the purpose of registering for a meeting (classes or consultations) at HKF Centrum and for preparing the appropriate interview based on the age of the person for whom services are to be provided at HKF Centrum, contacting the Client or their guardian to schedule, reschedule, or cancel meetings, and maintaining and storing accounting and financial documentation.

• Name, surname, phone number, and email address – for the purpose of registering for training or webinars organized by HKF Centrum, contacting the Client to schedule, reschedule, or cancel training or webinar dates, and maintaining and storing accounting and financial documentation.

• Health-related information – to gather an interview regarding the Client’s health status, determine the absence of contraindications to providing services within therapy, where gathering and evaluating this type of data is necessary for the safe and proper provision of services at HKF Centrum.

• Data indicated in the above points – for archival (evidential) purposes in case of a legal need to demonstrate facts or specific circumstances or to establish, pursue, or defend against claims.

• Facial image – for the purpose of conducting video surveillance (without audio recording) in rooms at HKF Centrum specified in detail in the General Terms and Conditions, to ensure the safety of Clients or their guardians and the employees and collaborators of the Service Provider, as well as to protect the property of HKF Centrum, i.e., for the protection of legally justified interests realized by the Service Provider, and in the case of separate and clear consent given by the Client or their guardian in connection with participation in group events for use (distribution) in promotional materials related to HKF Centrum in the media, including on websites and social media platforms.

• Facial image and/or voice (depending on the scope of consent given for recording) – for the purpose of supplementing the diagnostic process (as auxiliary materials).

• Email address – only if separate consent is given for receiving the newsletter – for sending newsletters regarding the activities of the Centrum, e.g., new services offered at the Centrum, information about events and activities organized at the Centrum.

2. Who or what allows for obtaining and processing data? (Legal basis for processing)

• Registration for meetings (classes, consultations) at HKF Centrum, preparing interviews, contacting to schedule, reschedule, or cancel meetings – processing is necessary for the performance of a contract to which the Client and their legal guardian are parties.

• Maintaining and storing accounting and financial documentation – processing is necessary for fulfilling a legal obligation imposed on the administrator.

• Pursuing payment for meetings canceled less than 24 hours before the scheduled meeting – processing is necessary for the purposes arising from the legally justified interests realized by the administrator, namely, pursuing claims of the administrator.

• Gathering and evaluating health information – the legal basis for processing this data is the consent of the Client or their guardian.

  Archiving (evidential) purposes – processing is necessary for the purposes arising from the legally justified interests realized by the administrator, namely, for the needs of establishing, pursuing, or defending the Service Provider against possible legal claims.

• Conducting video surveillance (without audio recording) – processing is necessary for the purposes arising from the legally justified interests realized by the administrator, namely, ensuring the safety of persons and property at HKF Centrum.

• Capturing images during group events (group classes, open days) and distributing such captured images in promotional materials related to HKF Centrum in the media – the legal basis for processing the data is the separate consent of the Client or their guardian.

• Capturing images and/or voices in recordings of diagnostic sessions – the legal basis for processing the data is the separate consent of the Client or their guardian.

  Sending newsletters – the legal basis for processing the data is the separate consent of the Client or their guardian.

3. Who else – besides the Administrator – will have access to my data? (Categories of data recipients)

• Specialists at HKF Centrum.

• Providers of IT systems and services, including the operator of the BOOKERO system used for registering for meetings at HKF Centrum.

• Consulting and advisory firms (e.g., providing accounting or property protection services).

4. Will the data be transferred outside of Europe? (Transfer of data outside the EEA/EU)

Based on personal data, decisions will not be made automatically, nor will they be transferred outside the European Economic Area or to an international organization.

5. What are my rights regarding the transfer of my personal data? (User rights/legal guardian of a minor User)

The right to access processed data, to rectify (if possible) or change it, to request deletion (if legally permissible), to restrict processing (if possible) or to transfer data, to withdraw consent for processing (if consent was the basis for processing), or to lodge a complaint with a supervisory authority, but this does not affect the legality of the processing carried out before the withdrawal of consent.