Welcome to the Team Puli community!

This notice summarises how we collect and process your personal data in relation to the provision of the Team Puli Services and what choices you have with respect to your privacy.

This notice does not apply to any third-party applications or software integrated with the Services (“Third-Party Services”), or to the privacy practices of any other third-party products, services or businesses.

What type of personal data do we process?

Why do we process your data?

• Services: We will use some of your personal data for the provision and maintenance of our Services, in particular in order to record the achievements attained during the Challenges.
• Billing: We will process certain information, such as financial data for billing purposes, i.e. to complete transactions, and send you purchase confirmations and invoices.
• Communication: We will send you information regarding the Services, such as administrative messages, to your email address provided to us. Please be aware that you cannot opt out of receiving certain service messages from us, including necessary security alerts and legal notices.
• Marketing: Upon your consent, we may use your email address to send you marketing communications. In order to understand how our users interacts with our Services, and to measure and understand how well an online marketing or email campaign performed, we perform analyses.
• Developing Services: We use analytics software to allow us to better understand the behaviour of our users to grow our business. This software records information, such as how often our Services are used, and the events that occur while using the Services. We use this aggregate information to identify usage patterns and trends.
• Protecting our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of our business.
• Other: We may also process your data for any other purposes for which we obtain your consent where necessary or otherwise in accordance with applicable law and this policy.

What is the legal basis of our data processing?

We collect and process information about you only where we have legal bases for doing so under applicable EU laws. This means we collect and use your information only where:

• It is necessary in order to provide you the Services, including to set up and maintain an account for you, to provide customer support;
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, and to protect our legal rights and interests;
• You give us consent to do so for a specific purpose;
• It is needed to comply with a legal obligation.

How do you use your data while using the Services?

To provide you with updated results of the Challenges, we continuously show you your daily steps as well as the total number of steps taken by you while using the application, your Lupi Coins and boosts in your User Account. This function enables you to follow your developments during different Challenges.

Via the Chat function, you may exchange messages with other participant of the Challenge. Don’t forget that – upon your decision – you may also send messages to all participants of the Challenge and such case, any participants of the Challenge will be able to read your message. Before you send a message, please always consider the rules set out in section 3 of the User Terms.

Do we share your data with third parties?

We never sell your personal data to third parties. However, in certain cases we need to share your personal data with others. In any case, we will share your personal data only in accordance with applicable laws and this notice, and in the following cases:

• Your Administrator: In order to record the results of the Challenges, as well as to decide regarding prices and awards (if applicable) of the Challenges, we will make summary reports available to your Administrator about the achievement of participants and teams.
• Other participants: To prevent a potential fraud or abuse of the rules, you may continuously follow the number of steps taken by other participants taking part in the Challenge. You can look up the number of steps individually, on the basis of the relevant participant’s user name – and other participants can also look up yours.
• Legal compliance: We may transmit personal data if the applicable legal provisions so require, or when such action is necessary to comply with any laws, e.g. with criminal authorities if we are required to cooperate for such purposes. We may also need to share personal data for the protection of our rights and interests, to protect your safety or the safety of others or to investigate fraud, in accordance with the applicable laws.
• Third-party service providers: In certain cases, we use third party data providers. For example, we may outsource billing and payment transactions to third parties. Our data processors always undertake to use the personal data shared only in relation to their services provided to FitPuli.

In principle, your data is stored within the territory of the EEA. We will only transfer personal data outside of the EEA in accordance with applicable laws.

Who is responsible for the processing of your data?

Team Puli services are provided FitPuli Kft. (registered seat: 9024 Győr, Katód utca 6. I/3., Hungary, registration number: Cg. 08-09-029303) (“FitPuli”). As our services are provided to your organization, the ultimate decisions regarding your personal data will be made by your company that qualifies as “Customer”. In such case, Customer will be considered as a controller and FitPuli will act upon the instructions of the relevant Customer, as a data processor.

In any case, certain activities of FitPuli are outsourced to third parties (processors), they may also use your personal data when acting on behalf of FitPuli. You can find more details about our sub-processors here.

How long will we process your data?

We will retain your personal data as long as it is needed to fulfil the purposes specified above (for example, to provide you with our Services, to enable your participation in a Challenge), unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it in accordance with our deletion policy.

If your personal data is held by us on behalf of your organization, we will retain such personal data as long as we are instructed to do so by the relevant Customer that is the controller of your personal data.

How do we protect your data?

We take appropriate technical and organizational measures to protect your personal data against any forms of unlawful processing. FitPuli is ISO27001:2013 certified.

Your privacy rights

You may ask us to:

• provide information to you about the personal data that we or our processors process about you,
• correct inaccuracies or amend your personal data,
• delete your personal data.

You can request this by send an email to dpo@fitpuli.com. We will respond to your request within thirty calendar days. Please note that, we may ask you to verify your identity before complying with the request.

You also have the right to complain to a data protection authority or claim damages before the court if necessary. For more information, please contact our supervisory authority, the Hungarian Data Protection Authority (Nemzeti Adatvédelmi és Információbiztonság Hatóság in Hungarian):

Mail address: 1530 Budapest, Pf. 5

Telephone: +36-1-391-1400

Fax: +36-1-391-1410

Email: ugyfelszolgalat@naih.hu

Website: http://www.naih.hu

A list of contact details for the EU data protection authorities is available here.

Any further questions?

If you have any further questions in relation to the processing of your data, please contact info@teampuli.com.

We have also appointed a data protection officer, whom you can contact:

Name: József Oláh

Email: it@fitpuli.com

Address: 9024 Győr, Katód utca 6. I/3., Hungary