Privacy policy

PRIVACY POLICY AND PRIVACY CODE OF CONDUCT

PRIVACY POLICY AND PRIVACY CODE OF CONDUCT
Spirit Hotel Ltd.
Company headquarters: 1061 Budapest, Andrássy út 2.

The purpose of the present policy (hereinafter as Policy) is to uniformly, clearly and comprehensibly regulate the data handling throughout the mySpirit Health program (hereinafter as mySpirit Health program) operated by Spirit Hotel Thermal Hotel Ltd (hereinafter as Spirit Hotel Ltd.) and thus fulfill a business practice which fully conforms with the relevant Hungarian laws in effect.
Spirit Hotel Ltd. feels it's important to uphold the provisions of the data protection regulation, which is why it created the present Policy to provide information to Clients on the main rules of data handling, the range of the handled data, the method of data handling and the purpose of the handling as well as other data handling-related issues.
Spirit Hotel Ltd. recognizes everyone's right to have access to information related to the automated stock of personal data, its main purposes as well as on the individual handling the data stock and its headquarters.
Furthermore, Spirit Hotel Ltd. recognizes everyone's right to notification - within reasonable intervals and without exaggerated costs - on whether their data is stored in an automated data stock and to be informed about said data in a comprehensible form; when necessary, said data should be replaceable or deleted in the simplest and most expedient manner; as well as for allowing due recourse in justified cases or when the right to information encoded in the law exists in the case of the failure to comply with requests of publication, correction and deletion.
Spirit Hotel Ltd. hereby informs its Guests of the data handling taking place throughout the mySpirit Health program, thus fulfilling its duty in accordance with the relevant laws, thus Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (hereinafter as Privacy Act):

1. The data handler:
Spirit Hotel Ltd. (headquarters: 1061 Budapest, Andrássy út 2.).
NAIH registration number:

 2. Range of handled data:
The range of data handled by Spirit Hotel Ltd. throughout the mySpirit Health program includes the following:
a) personal identification data: surname and first name, maiden name, sex, place and time of birth, mother's maiden name and surname, permanent place of residence, place of residence, social security number (hereinafter as TAJ number) - collectively or individually all of the above insofar as they are suitable for personal identification;
b) health data: any perceived, examined, measured, mapped data related to the concerned individual's physical, intellectual or mental condition, harmful addiction, or any other data pertaining to the circumstances of disease or demise or reasons thereof including data provided by the individual or others in relation to them, as well as the network of medical care; furthermore data of all nature which can be tied to the above (for example, behavior, environment, occupation);
c) voluntarily provided data: phone number, email address

3. Purpose of the data handling:
Spirit Hotel Ltd. will notify the concerned party prior to the recording of the data whether the provision of data is voluntary or obligatory. The purpose of the handling of obligatorily provided personal data is its usage by Spirit Hotel Ltd. throughout the mySpirit Health program for the utilization of services during the Health program, the identification of the Guest, and providing for the possibility of communication between Spirit Hotel Ltd. and the individual benefitting from the services.
In the case of health and personal identification data, Spirit Hotel Ltd. will act pursuant to Act XLVII of 1997 on the handling of personal data and their protection.
In accordance with the provisions of said act, the purpose of the handling of health and personal identification data includes the following:
a)    facilitating the preservation, improvement and sustainment of health,
b)    facilitating the effective treatment activities of the healthcare institute, including its professional review activities,
c)    the tracking of the health condition of the concerned party,
d)    carrying out common health, public health and epidemiological measures,
e)    validating patient rights.
The purpose of the handling of optional data is to provide said information to Spirit Hotel Ltd. based on the voluntary and expressed decision of the Guest. Without the consent of the Guest based on preliminary information, the data will not be used for purposes beyond those designated above and will not be issued to any third parties. The handling of the designated data is carried out with the voluntary consent of the Guest.
The provision of certain data is obligatory during the registration – which are thus tied to benefitting from the service – and which are indispensible for utilizing the service, without which the registration cannot be carried out effectively. The range of obligatorily provided information includes the following: name, place and time of birth, TAJ number, address, phone number, e-mail address.

Spirit Hotel Ltd. will forgo carrying out any sanctions or imposing any disadvantages against Guests who deny the obligatory provision of data. The data handling of Spirit Hotel Ltd. within the scope of the current policy extends to all data provided by Guests.

4. Information on and the duration of the data handling:
We will provide our Guests with unambiguous and detailed information on the range of personal data included in item no. 2 above, particularly the purpose and legal grounds of the data handling, the individual authorized for data processing, the duration of the data handling and the range of parties with access to the information. The information provided by Spirit Hotel Ltd. extends to the concerned party's rights and their options for legal remedies.

The data handler will provide, upon request, written information on the range of the handled data, the purpose, legal grounds, and duration of the data handling, as well as the name, address (company headquarters) of the data processor and its data handling-related activities, furthermore the range of individuals who received access to the data and for what purpose this access was provided. Information may be requested by all parties through the mail address of the data processor by providing a response mail address.

At the request of our Guests, we will modify, correct, lock or delete their data from our system. Requests of this nature are to be forwarded to the following mail address (…………), or via e-mail to the ………….@spirithotel.hu e-mail address. We hereby inform all parties that consensual data handling will be carried out until the withdrawal of the Guest's consent.
 
5.  The range of individuals with access to the data, data processors:

Only designated employees of Spirit Hotel Ltd. will have access to the personal, non-public information provided by the Guests. Under no circumstances will Spirit Hotel Ltd. provide the personal data it handles to any third party or parties - with the exception of binding cases prescribed in the relevant effective legislative measures - without the permission of the concerned party.

Our firm will take the necessary measures in order to provide for the safe storage of handled data as well as to avoid its unauthorized usage and any related abuses.

Spirit Hotel Ltd is aware that the data handler and - in the scope of its activities - the data processor is required to provide for the safety of the data and moreover is required to take the necessary technical and organizational measures and developmental procedural rules which are necessary to validate the law, including additional data and confidentiality rules.

The data - particularly personal data qualified as state or professional secrets - must be protected from unauthorized access, modification, publishing, deletion, damage and destruction.

Data can only be forwarded and the various data handling measures can only be linked if the concerned party consented to such measures or if allowed by law and the conditions of the data handling are fulfilled for every single piece of personal information.

6. The rights of Guests concerning the handling of their personal data; data deletion:
Spirit Hotel Ltd. undertakes to provide an obvious, clear notice to its Guests before the recording, securing and handling of any of their data in which they inform the Guests of the method, purpose and principles of the data recording.
Throughout the data handling, Spirit Hotel Ltd. will do the utmost to validate the following principles:
At the request of the concerned party, the data handler will provide information on the range of the handled data, the purpose, legal grounds, and duration of the data handling, as well as the name, address (company headquarters) of the data processor and its data handling-related activities, furthermore the range of individuals who received access to the data and for what purpose this access was provided.
The data handler is required to respond to requests in writing within the shortest possible time, yet within 30 days at the most, providing information in a comprehensible manner. In the case of the infringement of the rights of the concerned party, the data handler may turn to a court of law. The data handler is required to reimburse any damages incurred through the unlawful handling of the concerned party or through the violation of the technical demands of data protection.
The data handler is also responsible towards the concerned party for damages caused by the data processor. The data handler is exempt of said liability if it can be demonstrated that the damage was caused by an unavoidable cause beyond the scope of the data handling. Damages are not reimbursable insofar as they were incurred through the intentional actions or gross negligence of the injured party.
In addition to the above, in all cases when the data recording, handling and securing is not required by law, Spirit Hotel Ltd. will inform the Guest of the voluntary nature of the data provision. In the case of required data provision, the law which calls for the provision of data must be indicated.

In all cases in which Spirit Hotel Ltd. wishes to use the provided data for purposes other than the original data recording, it will undertake to inform the Guest of such circumstances and will endeavor to gain their preliminary, expressed consent and will provide for an opportunity to forbid said measures.

7. Principles to be validated throughout the data handling

Spirit Hotel Ltd. hereby publishes its data protection and handling policy, which it will consider to be bound by and will take all necessary measures to validate said policy.
Spirit Hotel Ltd. undertakes to
a)    provide for the safety of data and will take all necessary technical and organizational measures and adopt procedural rules which ensure that the recorded, stored and handled data would be protected and will prevent their destruction, unauthorized usage or modification.
b)    call upon all third parties to whom the data will possibly be forwarded or delivered, to fulfill said obligations.
c)    When developing the present policy, Spirit Hotel Ltd. took special care to adopt the provisions of Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, Act VI of 1998 on the Protection of Individuals during the Automated Processing of Personal Data, as well as the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data adopted in Strasbourg on 28 January, 1981.
d)    The purpose of the present data handling policy is to provide for the observance of the rights - in particular the right to privacy - and fundamental freedom rights of all individuals in all aspects of the services of Spirit Hotel Ltd. regardless of nationality or place of residence throughout the automated processing of personal data (data protection).
Spirit Hotel Ltd. also observes the following personal data requirements during the automated processing of data:
a)    data can only be gained and processed in a decent, lawful manner;
b)    data can only be stored for defined and lawful purposes and cannot be carried out in any different manner;
c)    the data must be proportionate to the purpose of their storage and must adhere and not go beyond said purpose;
d)    the data must be precise and, if necessary, timely;
e)    the method of data storage must allow for the identification of the subject of the data only as long as allowed for by the purpose of the data storage,
f)    automated processing is not allowed for data pertaining to racial origin, political preferences, religion or any other beliefs including personal data pertaining to health and sex life, unless the domestic law provides the appropriate background for this.
g)    Suitable safety measures must be taken for the protection of personal data stored in automated data stock in order to prevent accidental or unlawful destruction, accidental loss as well as unauthorized access, modification or dissemination.

8. Information on legal remedies and enforcement options

We kindly ask you to contact Spirit Hotel Ltd. should you feel that it violated your right to the protection of personal data in order to remedy any possible legal infringements.
We hereby inform you that based on the contents of Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, you may contact the Hungarian National Authority for Data Protection and Freedom of Information in the case of any possible legal infringement and may validate your claims at a court of law. The detailed provisions on this matter as well as on the duties of the data handler are contained in Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information. The contact information of the Hungarian National Authority for Data Protection and Freedom of Information are as follows:
Mail address: 1530 Budapest, Pf.: 5.
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
Telephone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
www: http://www.naih.hu
e-mail: ugyfelszolgalat@naih.hu

8. Miscellaneous:
Spirit Hotel Ltd. reserves the right to modify its privacy policy. This is particularly relevant in cases which are allowed by law. The modification of the data handling procedures cannot constitute the usage of personal data for purposes beyond those defined above.
In all cases, data will be handled according to Section 5 paragraph (1) item a) and paragraph (2) item a) of Act CXII of 2011 as well as according to Act XLVII of 1997.

9. Exclusion of the liability of Spirit Hotel Ltd.:
Insofar as Spirit Hotel Ltd. learns of any instances of Guests providing the personal data of others in a way which breaches the present policy, or which impedes the rights of any third parties, or in any other unlawful manner or uses publicly available or unlawfully gained personal or other data in an unlawful manner (for example, for direct marketing purposes), or violated the provisions of the present privacy policy in any other way or has caused damages of any nature through registration, Spirit Hotel Ltd. will take the necessary legal measures in order to settle the damages caused as well as to legally impeach the perpetrator.
In such cases, Spirit Hotel Ltd. will provide all necessary assistance to the acting authorities in order to determine the identity and impeach the offender.

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