(Last modified 11th April, 2023)

Privacy Policy for Customers, Suppliers, Business Persons, Website and Application Visitors, Employees and Applicants

Information about ALSAD (Automated LifeStyle ADvice)

Welcome to the https://www.alsadmedical.com  website (including its subdomains, contents, trademarks and services, referred as “website” hereinafter).

Who we are?

The rights to dispose, including operation and maintenance of the ALSAD Application and the website are fully owned by ALSAD Medical Ltd. (located at Váci út 45. 1134 Budapest Hungary, tax number: 26684802-2-41, registration number: 01-09-414690, hereinafter referred as „ALSAD Medical” ).

Protecting the security and privacy of your personal data is important to us. For this reason, ALSAD Medical processes personal data in compliance with applicable laws on data protection and data security according to applicable data protection and data security law, especially in accordance with General Data Protection Regulation (EU) 2016/679 (GDPR) of European Parliament and European Commission, the Hungarian Act CXII of 2011 Informational Self-determination and Freedom of Information and Data Protection Act 2018 (UK GDPR).

BY USING THE WEBSITE OR OUR WEB APPLICATION, YOU AS A USER ARE AGREEING TO THE PRACTICES AS STATED IN THIS POLICY (AS UPDATED OR AMENDED FROM TIME TO TIME) AND OUR TERMS OF USE. USING OUR WEBSITE OR WEB APPLICATION YOU DO GIVE YOUR CONSENT TO PROCESS YOUR PERSONAL DATA ACCCORDING TO TERMS AND CONDITIONS STATED IN THIS POLICY. IF YOU DO NOT AGREE TO THE TERMS AS STATED ABOVE, PLEASE STOP USING THIS WEBSITE OR WEB APPLICATION IMMEDIATELY.

This Privacy Policy applies to all the personal information we collect about you when you interact with us through our website, applications or other forms of communication.

These interactions may occur when you:

• visit our website;
• use our web app;
• use or purchase our products or services;
• subscribe to our newsletters, participate in our online communities, games and other competitions;
• contact our customer support;
• request information specific to your interests;
• offer us products or services;
• interact with us as an employee or applicant.

We may process several types of personal information about you depending on your capacity as e.g. a consumer, costumer or business partner, and the ways you interact with us.

If you choose not to provide us with your personal information, please understand that we might not be able to provide you with the requested product, service, solution or respond to some of your requests.

Contact information (name, address, email, telephone etc.);

Account login information: usernames, passwords;

General Business information such as address, contact person, invoicing and other payment information, delivery information.;

Reviews, feedback, comments;

Audiovisual information, such as images or video;

Recruitment data: CV, application forms, letters of recommendation, languages, qualification, certifications, trainings, and other professional licenses, etc.;

Talent management information, such as employment and education history, other details included in the CVs; professional qualifications and experience, performance and development programs and reviews and career development plans, etc.

Information regarding your health, health goals, body measurements, allergies, activity level, taste in food, food intake, exercise, sleep, and other information that you voluntarily provide us.

Information which part of the voluntary health tests as provided in the application, including answering questions about your age, date of birth, gender, ethnicity, dietary and medical history, family health history, exercise history and body measurements.

Information that you provide us by means of our App, such as, without limitation, feedback and responses to recommended dishes, menus, recipes, packaged foods and restaurant meals.

Traffic information such as time and/or duration of your interaction with us

IP address, MAC address of the devices with which you interact with us.

Location information (meaning your actual location defined by the information mentioned above);

Information related to your interests (products or services that you are visiting on our website platforms);

Cookie preferences.

Depending on the role/objective you may have when you visit the Site /use the Application, we may collect personal information for different purposes.

Services: Your information may be required in order to provide you with the requested goods or services or to fulfil other purposes which you have requested from us, as well as further develop, customize and improve our services.

Support: Providing you with customer support, responding to your questions or requests, to maintain account security and for other website or app maintenance reasons.

Marketing: To facilitate direct marketing, promotions, newsletters and website analysis.

Legal: Performance and execution of contracts, due diligence and compliance with our legal obligations.

Under Article 6 (1) of the UK GDPR, we are only permitted to process your data if there is a legal basis to do so. A legal basis for processing your data will arise when one or more of the following conditions apply:

(a) Consent: you have  given clear consent to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract between us, or because specific steps have to be taken before entering into a contract.

(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary to perform a task in the public interest or for   official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for our legitimate interests of ALSAD Medical or the legitimate interests of a third party, except where your interests or fundamental rights and freedoms which require protection of personal data override such interests.  

We retain your personal information as long as it is necessary to fulfil the specific purposes, as explained under the section “Why we collect your personal information”. In specific cases, a longer retention of your personal information might be required according to legal obligations. We keep your data until it is required according to period of prescription, duration of storage and retention period set by civil law, tax law and accounting rules.

This Privacy Notice applies exclusively to ALSAD and the products or services of ALSAD Medical, and not to other websites or applications operated by third parties.

We do not integrate any social media plugins directly into our website. Therefore, your data will only be transferred to the extent that we additionally inform you on our Cookie Policy. Our website may contain links to social media or other third-party sites or applications. ALSAD Medical is not responsible for the privacy practices of such other websites or applications. We recommend that you review the privacy policy of any third-party sites or links you may choose to visit for further information.

Additional Third-Party Information

You may connect our Services to Third-Party Applications or Devices. If you use the Services by logging on a Third-Party Application or by connecting to a Third-Party Application or third-party device we may also receive personal information about you which is provided by such Third-Party Application, and/or Third-Party Devices including information regarding health, lifestyle and exercise activities.
Please check the policies of such Third-Party Application and/or third-party devices in order to understand what information we receive.

If we will enable direct payment through our Services, we will collect and store billing and credit card information.

We also use third-party service providers and business partners in the health, medical and/or fitness field to offer you additional products and services. If you choose to use these products or services, we may share your personal data with them to the extent necessary for such providers to offer you their products or perform their services. Accordingly, we encourage you to review any third-party’s privacy policy for further information.

When you visit our websites or in our digital platforms in general, cookies might be stored on your devices within the web browser. Cookies are small text files that can store information for a certain period and identify your device. We use cookies in order to provide you the possibility to use our platforms in an easy way tailored to your interests and preferences. Please read our Cookie Policy and learn more on how we use cookies or other tracking technologies.

We take reasonable steps to implement appropriate technical and organizational measures to protect your personal information. These measures are in compliance with applicable data protection and data security laws and are in place to prevent any risks, such as accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal information.

Our measures to protect your data include:

• limiting physical access to our premises;
• limiting access to personal information;
• requiring third-party providers to have acceptable security measures to keep personal information secure; and
• putting in place physical, electronic, and procedural safeguards in line with industry standards.

ALSAD does not sell or license your personal information to third parties.

Except as stated in this Privacy Policy and in specific cases, where an appropriate legal basis exists, ALSAD Medical does not share personal data with third parties.

We may disclose your personal information to:

• ALSAD parent company or possible affiliates.
• External service providers such as consultants, advisors and auditors to the necessary and sufficient extent. We may also share your data with trusted service providers who support us in providing you with services such as IT (cloud) services, marketing, finance, advertising, archiving and document storage.
• Public or governmental authorities as required by applicable laws and regulations.

Where required by law, the appropriate data processing agreements have been concluded with these third parties.

From 1 January, 2021, the Data Protection Act 2018 (UK GDPR) controls how personal information of UK residents is used by organisations, businesses or the government.

All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner.

According to the Terms of Use the website and the application is only intended for individuals aged 14 years or older. For minors who are legally incapacitated (eg. under 14 years) visiting or using the website and the application is not permitted, therefore we do not process their data.
If you have only limited legal competence (like minors over 13 and under 18 years of age as per UK GDPR), then you must review these Terms with you parent or guardian before visiting or using the Site or Application to make sure that you and your parent or guardian understand these Terms and agree to them.
If you are between the age of 13-18, talk to your parents or legal guardians and obtain their consent before sharing your personal information with us.
If you are a parent or legal guardian of a child between the age of 13-18, we ask that you supervise your children’s use of our products or services (including websites and other digital platforms) and make sure that your children do not and will not share any personal information with us without asking your permission to do so.

As a data subject, you have certain rights as relates to the processing of your personal data, as per UK GDPR (General Data Protection Regulation). These rights include:

• The right to be informed.
• The right of access.
• The right to rectification.
• The right to erasure.
• The right to restrict processing.
• The right to data portability.
• The right to object.
• Rights in relation to automated decision-making and profiling.

You may exercise these rights by contacting us directly. All questions or requests regarding personal data should be sent to:

Address: Váci út 45. 1134 Budapest HU
Phone number: +36 1 8781653
E-mail:

Upon receiving your request or questions, you will be asked to verify your identity and specify which kind of information you require.

ALSAD Medical aims to ensure that your request will be addressed within one month and free of charge unless a disproportionate effort is required.

You can submit a claim to ALSAD Medical to access, correct, delete limit data processing of your personal data. You can also submit an objection against data processing and you can claim your right for data portability. If you believe that the processing of your data is in conflict with the data protection legislation, you also have the right to contact your local data protection authority and you can withdraw your consent at any time.

You can submit a complaint to to the  ICO – Information Commissioner’s Office, United Kingdom, using the following links:

https://ico.org.uk/make-a-complaint/

https://ico.org.uk/make-a-complaint/your-personal-information-concerns/

or use the ICO Helpline (from UK  on 0303 123 1113)

Our Data Protection Officer

You also have the right to contact our data protection officer.
The contact details of our data protection officer are as follows:

Zoltan Mathe
Tel.: +36 1 8781653
E-Mail:
Web: www.netis.hu