Privacy Policy

Version binding as of 9 December 2020.

 

Table of contents:
Click the link below to go to the selected section:

 

1. General information

2. What does personal data security mean to us?

3. Personal data – what does it mean?

4. What is the processing of data?

5. Who is the controller of your personal data and what does it mean

6. How to contact us with respect to the processing of your personal data? How to contact our Data Protection Officer?

6.1. Client of the Fitness Club (Zdrofit, S4, My Fitness Place, Form Factory, StepOne, Fitness Academy, Wesolandia or any of our other Clubs)

6.2. All persons other than clients of Fitness Clubs referred to in point 6.1
6.3. Contact details of the Data Protection Officer

7. In what way do we process your personal data?

7.1. Common information for all categories of persons listed in points 7.2-7.10 below.
7.2. Person visiting our websites or using our mobile application without logging in/registration
7.3. Person using our websites or mobile application as a registered user
7.4. Participant of our contest or lottery
7.5. User of the MultiSport Card
7.6. User of the MultiLife Programme
7.7. Client of the Fitness Club (Zdrofit, S4, My Fitness Place, Form Factory, StepOne, Fitness Academy, Wesolandia or any of our other Clubs)
7.8. Party to the contract concluded with Benefit Systems or a representative or a contact person of an entity being a party to the contract concluded with Benefit Systems, e.g. representative of the Client, Partner
7.9. Person contacting us via our hotline or another dedicated communication channel
7.10. Candidate for work

8. Marketing
8.1. General information
8.2. Online marketing
8.3. Marketing communication via the selected communication channel (e.g. e-mail, SMS/MMS, telephone, chatbot)
8.4. What is profiling for marketing purposes?
8.5. Our legitimate interest vs. your interests, rights and freedoms
8.6. How long will we process your personal data for marketing purposes for?
8.7. Objection pertaining to direct marketing

9. What rights do you have?

10. Amendments to the privacy policy

1. General information

Benefit Systems SA, with its registered office in Warsaw, Pl. Europejski 2, 00-844 Warszawa (hereinafter: “Benefit Systems,” “we”) attaches great importance to the protection of personal data. We endeavour to ensure that your personal data are processed in compliance with applicable Polish regulations and EU regulations, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: “GDPR”).


This document describes legal grounds for the processing, as well as methods of the collection and use of your personal data, and actions taken by us with respect to your personal data. The purpose of this document is also to inform you about the rights you have in relation to the processing of your personal data by us.

 

2. What does personal data security mean to us?

Benefit Systems understands the importance of security of data that remain under our control. We have implemented personal data processing policies and procedures, we carry out regular trainings on data protection, we conduct regular checks of applied security models in view of their adequacy in the context of the security of data we process.

 

3. Personal data – what does it mean?
Personal data are any information relating to an identified or identifiable natural person (e.g. first name and surname, e-mail address, MultiSport card number, IP address).

 

4. What is the processing of data?
Processing means any activities and operations which are performed on your personal data (e.g. collection, storage, erasure or analysis).
Our objective is to maintain the transparency of the grounds and the method of the processing of personal data.
It is our policy to collect the personal data only when it is necessary to achieve specific purposes, and we ask to provide personal data only when necessary.

 

5. Who is the controller of your personal data and what does it mean?
Benefit Systems (Benefit Systems SA, with its registered office in Warsaw, Pl. Europejski 2, 00-844 Warszawa) is the controller of your data.
This means that Benefit Systems decides about the purposes and methods of the processing of your personal data, i.e. how and to what end your personal data will be used.

 

6. How to contact us with respect to the processing of your personal data? How to contact our Data Protection Officer?


6.1. Client of the Fitness Club (Zdrofit, S4, My Fitness Place, Form Factory, StepOne, Fitness Academy, Wesolandia or any of our other Clubs)

You can contact us in the following way:
1) by post to the following address: Benefit Systems S.A. Fitness Branch, Pl. Europejski 2, 00-844 Warszawa, with the “Personal data” note;
2) by e-mail: daneosobowe@fitness.benefitsystems.pl.


6.2. All persons other than clients of Fitness Clubs referred to in point 6.1
You can contact us in the following way:
1) by post to the following address: Benefit Systems SA, Pl. Europejski 2, 00-844 Warszawa, with the “Personal data” note;
2) by e-mail: daneosobowe@benefitsystems.pl;
3) by telephone at: 22 242 42 42;
4) by using the contact form available at: https://www.benefitsystems.pl/formularz-dane-osobowe/.

6.3. Contact details of the Data Protection Officer
We have designated a Data Protection Officer whose details are available at www.benefitsystems.pl. The Data Processing Officer can be contacted in all matters related to the processing of your personal data by us and exercising the rights you are entitled to in accordance with the GDPR. You can contact the Data Protection Officer by e-mail, at: iod@benefitsystems.pl, and by post to the following address: Benefit Systems SA, Pl. Europejski 2, 00-844 Warszawa, with the “DPO” note.

 

7. In what way do we process your personal data?
The method of the processing of your personal data depends on the relationship between you and Benefit Systems. Information on the data processing for the most common categories of persons is presented below.


Categories of persons listed below are not all categories of persons whose data are processed by us. If you do not belong to any of the categories listed below, but you would like to obtain additional information on the processing of your personal data, please contact us. Contact details are in point 6 above.
If you belong to any of the categories of persons listed below, it may happen that, due to the specifics of using our services by you, we will process your personal data in a way other than described in points 7.2.-7.10. below. In such case, we will always notify you thereof before we start to process your data.

 

7.1.Common information for all categories of persons listed in points 7.2-7.10 below.


Is the provision of data obligatory?
In general, the provision of data is not obligatory, but may be necessary to use the services provided by Benefit Systems, e.g. to conclude the contract with us, participate in a contest or to examine your case. Consequently, in some cases, failure to provide data can result in an inability to provide services by us. Our forms used to collect data explicitly identify data, the provision of which is necessary.


To whom are your data transferred?
Your personal data can be transferred to the following entities: entities of the Benefit Systems Group, entities providing hosting services and maintenance of our websites or applications, entities providing tele-information services, as well as IT support and security services, entities providing services involving storage and destruction of data media, entities providing services related to service of our clients and other stakeholders (e.g. couriers), as well as supporting our marketing activities, legal advisors and entities conducting audits.
Your data can also be transferred to public authorities if the disclosure is provided for by the law.
The aforementioned list of entities, to whom your data are transferred, was supplemented to the extent necessary, taking into account particular categories of persons listed in points 7.2.-7.10. below.


Do we transfer your data to countries outside the European Economic Area?
As a rule, your personal data are not transferred outside the European Economic Area (EEA). Some entities, to whom we may transfer your data, have their registered offices outside the EEA. We make every effort to ensure that data are transferred in compliance with the law and to implement suitable safeguards. In particular, this includes using standard contractual clauses approved by the Commission. You may contact us in order to obtain a copy of the safeguards used. Contact details are in point 6 above.


What are your rights in relation to the processing of your data by us?
Your rights are described in detail in point 9 of the Policy (“Rights of a data subject”).

 

7.2. Person visiting our websites or using our mobile application without logging in/registration


What data are processed by us?
We process data pertaining to your device, on which you use our website or the application: IP address, data stored in cookies or other similar technologies (see: “Policy on cookies and other similar technologies”). We also process data pertaining to your activities on pages in our website or in the application, such as information on your preferred activities or activity places. Additionally, we process data including content of HTTP requests sent to our server from your device (URL address, IP address, browser details, request date and time, HTTP response status code, information on errors, cookie identifier, browsed site resources). Data collected in such a way are saved in server logs.


If you grant your consent, we also process data pertaining to your location.


What is the purpose of and legal ground for the processing of your data?

  • We process your data for the purposes of providing to you the service involving access to our website or mobile application. We process your data, because it is necessary for the performance of the contract concluded by you with Benefit Systems, i.e. contract for the provision of services by electronic means, in accordance with the rules of the particular website or mobile application (legal ground – point (b) of Article 6(1) of the GDPR).
  • We process your data for the purposes of administration of the server, ensuring its security and for statistical purposes. We act on the basis of our legitimate interest involving the server administration, identification of errors in the structure of our websites and keeping statistics of the most frequently used resources (legal ground – point (f) of Article 6(1) of the GDPR).
  • Location data are processed in order to show, in the search engine, the facilities available in the MultiSport Programme or MultiLife Programme that are the closest to your location (legal ground – point (a) of Article 6(1) of the GDPR).


How long will we keep your data for?
We process your data for the period of using our website or mobile application by you, and after you end using our website or mobile application, we will process your data for the period, for which these data remain recorded in the server logs.


Processing of data for marketing purposes
In relation to using our website or the mobile applications, your personal data can also be processed for marketing purposes, including profiling. Related information is presented in point 8 below (“Marketing”).

 

7.3. Person using our websites or mobile application as a registered user
If you use our websites or mobile application as a registered user, information presented in point 7.2 above also applies to you.


What data are processed by us?
If you set up an account in one of our websites or in the mobile application, we process your data that you provided in the registration form. We also process data disclosed by you when using the account in the service or the application, pertaining to your activities (e.g. details of visited pages and sub-pages in our websites, time of visits, etc.) on pages in our website or the application. Sometimes, in order to use certain functionalities in the service, you will be asked to provide special categories of data, e.g. data pertaining to the health status (e.g. in the case of diet or pro-health services).


What is the purpose of and legal ground for the processing of your data?

  • We process your data for the purposes of providing to you the service involving maintaining the account on our website or in mobile application. We process your data, because it is necessary for the performance of the contract concluded by you with Benefit Systems, i.e. contract for the provision of services by electronic means, in accordance with the rules of the particular website or mobile application (legal ground – point (b) of Article 6(1) of the GDPR).
  • We process your data in order to facilitate using our websites or mobile application, on the ground of our legitimate interest involving the improvement of functionalities of services provided by us by electronic means (legal ground – point (f) of Article 6(1) of the GDPR).
  • If special categories of data are collected for the purposes of the provision of services to you, your personal data are processed based on your explicit consent (point (a) of Article 9(2) of the GDPR). Data are always provided voluntarily, but the provision of data can be required in order to use the particular functionality of the service.
  • We process your data for tax and accounting purposes if our website or mobile application are used against payment. Data are processed, because it is required by applicable legal regulations (legal ground – point (c) of Article 6(1) of the GDPR).
  • We process your data for the purposes of the establishment, exercise or defence of legal claims. We act on the basis of our legitimate interest involving the exercise or defence of legal claims (legal ground – point (f) of Article 6(1) of the GDPR).

How long will we keep your data for?
We will keep your data your data for the period specified below:

  • for the purposes of providing to you the service involving maintaining the account on our website or in mobile application – until you delete the account;
  • for tax and accounting purposes – for the period consistent with applicable regulations;
  • for the purposes of the exercise or defence of legal claims – until the expiry of the property claim limitation period.

To whom are your data transferred?
In addition to entities listed in point 7.1 above, your data can be transferred to entities cooperating with us that offer additional services to you in relation to your account maintained on our website or in the mobile application, operators of social media, and if you use paid services provide by us, also to payment operators and entities engaged in the recovery of debts.


Processing of data for marketing purposes
In relation to using our website or applications as a registered user, your personal data can also be processed for marketing purposes, including profiling. Related information is presented in point 8 below (“Marketing”).

 

7.4. Participant of our contest or lottery


What data are processed by us and how have we obtained these data?
The scope of personal data collected for the purposes of the contest or lottery depends on the nature and rules of the particular contest or the lottery. Information thereon will be provided upon entering the particular contest or lottery.


What is the purpose of and legal ground for the processing of your data?

  • We process your data for the purposes of performance of the contest or the lottery, including identifying the winner, issuance of awards, publication of personal data of the winner and examining complaints or claims related to your participation in the particular contest or lottery, on the ground of our legitimate interest (point (f) of Article 6(1) of the GDPR).
  • We process your personal data for tax and accounting purposes, in the case of winning the award. Your data are processed, as this is required by applicable legal regulations (legal ground – point (c) of Article 6(1) of the GDPR).

How long will we keep your data for?
We keep your personal data for the period of the contest or the lottery you participate in. However, in certain instances, these data can be kept longer:

  • for the purposes of examining your complaint or claim pertaining to your participation in the contest or the lottery – until the expiry of the claim limitation period. We act on a basis of our legitimate interest, involving the protection of our rights and defence of legal claims (point (f) of Article 6(1) of the GDPR);
  • for tax and accounting purposes – for the period consistent with applicable regulations.

Processing of data for marketing purposes
If you are interested in receiving marketing messages via a selected communication channel, your personal data are also processed for marketing purposes, including profiling. Related information is presented in point 8 “Marketing”.


7.5. User of the MultiSport Card


What data are processed by us and how have we obtained these data?
In relation to joining the MultiSport Programme, we process your data, such as for instance identification data, contact data, data pertaining to using our services by you (including services of Partners and suppliers of additional services offered in relation to the MultiSport Programme). We receive these data directly from you, e.g. through the registration form, from our Client, i.e. the entity that enabled you to use the MultiSport Programme, or a person, who ordered the card for you at the Client (identification data, contact data), as well as from suppliers of additional services offered in relation to the MultiSport Programme.


What is the purpose of and legal ground for the processing of your data?

  • We process your data for the purposes of the provision of the service related to using the MultiSport Programme, as you granted your consent thereto (legal ground – point (a) of Article 6(1) of the GDPR).
  • We process your personal data for tax and accounting purposes, as this is required by applicable legal regulations (legal ground – point (c) of Article 6(1) of the GDPR).
  • We process your personal data for the purposes of the establishment, exercise or defence of legal claims. We act on the basis of our legitimate interest involving the exercise or defence of legal claims (legal ground – point (f) of Article 6(1) of the GDPR)

How long will we keep your data for?
We will keep your data for the period specified below:

  • for the purposes of the provision of services related to the participation in the MultiSport Programme – until resignation from the MultiSport Programme or withdrawal of your consent, whichever occurs first;
  • for tax and accounting purposes – for the period consistent with applicable regulations;
  • for the purposes of the exercise or defence of legal claims – until the expiry of the claim limitation period.

To whom are your personal data transferred?
In addition to entities listed in point 7.1 above, your data can also be transferred to Partners (sport and recreation facilities), suppliers of additional services available within the framework of the MultiSport Programme, Client (entity that enabled you to use the MultiSport Programme), payment operators and entities printing the MultiSport Card.


Processing of data for marketing purposes
Your data are processed for marketing purposes, including profiling. Related information is presented in point 8 “Marketing”.


7.6. User of the MultiLife Product


What data do we process and how have we obtained these data?
In relation to joining the MultiLife Programme, we process your data, such as for instance identification data, contact data, data pertaining to using our services by you (including services of Partners offering services to you in relation to the MultiLife Programme). We receive these data directly from you, i.e. through the registration form, from our Client, i.e. the entity that enabled you to use the MultiLife Programme, or a person, who reported you for the MultiLife Programme, at the Client (identification data, contact data), as well as from Partners offering services to you in relation to the MultiLife Programme.


What is the purpose of and legal ground for the processing of your data?

  • We process your data for the purposes of the provision of services related to using the MultiLife Programme, because you granted your consent thereto (legal ground – point (a) of Article 6(1) of the GDPR).
  • We process your data for tax and accounting purposes. We process your data, because it is required by applicable legal regulations (legal ground – point (c) of Article 6(1) of the GDPR).
  • We process your data for the purposes of the establishment, exercise or defence of legal claims. We act on the basis of our legitimate interest involving the exercise or defence of legal claims (legal ground – point (f) of Article 6(1) of the GDPR).

How long will we keep your data for?
We will keep your data for the period specified below:

  • for the purposes of the provision of services related to the participation in the MultiLife Programme – until resignation from the MultiLife Programme or withdrawal of your consent, whichever occurs first;
  • for tax and accounting purposes – for the period consistent with applicable regulations;
  • for the purposes of the establishment, exercise or defence of legal claims – until the expiry of the claim limitation period.

To whom are your personal data transferred?
In addition to entities listed in point 7.1 above, your data can also be transferred to Partners offering services to you in relation to the MultiLife Programme, Client (entity that enabled you to participate in the MultiLife Programme) and payment operators.
Processing of data for marketing purposes
Your personal data are processed for marketing purposes, including profiling. Related information is presented in point 8 below (“Marketing”).


In order to use the MultiLife Product, the User must register in the User Zone or the MultiSport Application. Within this scope – i.e. the User having an account in the User Zone or in the MultiSport Application – data of the Users are processed in compliance with principles described in point 7.3. above. At the same time, services available in relation to the MultiLife Programme in the User Zone or in the MultiSport Application can be accessed in keeping with principles described in this point 7.6.

 

7.7. Client of the Fitness Club (Zdrofit, S4, My Fitness Place, Form Factory, StepOne, Fitness Academy, Wesolandia or any of our other Clubs)


What data do we process and how have we obtained your data?
We process your data, such as for instance identification data, contact data, data pertaining to using our services by you (including services of entities cooperating with us that offer additional services to you in relation to having the membership card of our Club).We obtain these data directly from you, e.g. when signing the contract for the club card in the selected Fitness Club or through the on-line form allowing the purchase of the card on-line, as well as from entities cooperating with us that offer additional services to you in relation to having the membership card of our Club.


What is the purpose of and legal ground for the processing of your data?

  • We process your data for the purposes of the provision of services related to using our Fitness Club. We process your data, because it is necessary for the performance of the contract concluded by you with Benefit Systems, i.e. the contract on the provision of services by our Club (legal ground – point (b) of Article 6(1) of the GDPR).
  • We process your data for tax and accounting purposes. We process your data, because it is required by applicable legal regulations (legal ground – point (c) of Article 6(1) of the GDPR).
  • We process your personal data for the purposes of the establishment, exercise or defence of legal claims. We act on the basis of our legitimate interest involving the exercise or defence of legal claims (legal ground – point (f) of Article 6(1) of the GDPR).
  • We process your data for the purposes of identification when entering our Club based on your image or for the purposes of its dissemination in promotion and advertising materials of our Club, because you voluntarily granted your consent thereto (legal ground – point (a) of Article 6(1) of the GDPR).

How long will we keep your data for?
We will keep your data for the period specified below:

  • for the purposes of the provision of services involving using services of our Fitness Club – until termination of the contract on using services of our Club;
  • for tax and accounting purposes – for the period consistent with applicable regulations;
  • for the purposes of the exercise or defence of legal claims – until the expiry of the claim limitation period;
  • for the purposes of using your image in order to identify you when entering our Club or for the purposes of its dissemination in promotion and advertising materials of our Club – until you withdraw your consent.

To whom are your personal data transferred?
In addition to entities listed in point 7.1 above, your data can be transferred to entities cooperating with us that offer additional services to you in relation to having the membership card of our Club, operators of social media, entities printing the cards, and if you use paid services provide by us, also to payment operators and entities engaged in the recovery of debts.


Processing of data for marketing purposes
Your personal data are processed for marketing purposes, including profiling. Related information is presented in point 8 below (“Marketing”).


7.8. Party to the contract concluded with Benefit Systems or a representative or a contact person of an entity being a party to the contract concluded with Benefit Systems, e.g. representative of the Client, Partner


What data do we process and how have we obtained your data?
If you are a party to the contract concluded with Benefit Systems, we obtain your data directly from you. If you are a representative or a contact person of an entity being a party to the contract concluded with Benefit Systems, we obtain your date from the entity being a party to the contract. We process your data, such as for instance identification data, contact data, and data pertaining your function.


What is the purpose of and legal ground for the processing of your data?

  • If you are a party to the contract concluded with Benefit Systems, we process your data for the purposes of the performance of this contract. We process your data, because it is necessary for the implementation of the contract (legal ground – point (b) of Article 6(1) of the GDPR).
  • If you are a representative or a contact person of an entity being a party to the contract concluded with Benefit Systems, we process your data for the purposes of concluding the contract with the entity represented by you and for the purposes of the performance of this contract. We act based on our legitimate interest involving the correct conclusion and implementation of the contract with the entity cooperating with us (legal ground – point (f) of Article 6(1) of the GDPR).
  • We process your data for the purposes of the establishment, exercise or defence of legal claims. The ground for the processing of your data is our legitimate interest (point (f) of Article 6(1) of the GDPR), involving the potential defence or exercise of legal claims.
  • We process your data for tax and accounting purposes. We process your data, because this is required by applicable legal regulations (legal ground – point (c) of Article 6(1) of the GDPR).

How long will we keep your data for?
We will keep your data for the period specified below:

  • for the purposes related to conclusion and performance of the contract – until the expiration or termination of the contract;
  • for the purposes of the establishment, exercise or defence of legal claims – until the expiry of the claim limitation period;
  • for tax and accounting purposes – for the period consistent with applicable regulations.

To whom are your personal data transferred?
In addition to entities listed in point 7.1 above, your data can be transferred also to suppliers of additional services available within the framework of cooperation with us (e.g. training services).


Processing of data for marketing purposes
If you granted your consent thereto, your personal data are processed for marketing purposes, including profiling. Related information is presented in point 8 below (“Marketing”).


7.9. Person contacting us via our hotline or another dedicated communication channel


What data do we process and how have we obtained your data?
We process your data that we obtain directly from you via different communication channels, e.g. contact form available on our websites of in mobile applications, telephone contact with our hotline, e-mail contact to all e-mail addresses published by us, chatbot, live chat.


What is the purpose of and legal ground for the processing of your data?

  • We process your data for the purposes of processing your case, including providing answers to your question or to examine a complaint made by you. The processing of data is carried out in response to your inquiry and on the ground of our legitimate interest (legal ground – point (f) of Article 6(1) of the GDPR), involving the processing of inquiries submitted to us, or in relation to the legal obligation (legal ground – point (c) of Article 6(1) of the GDPR) imposed on us by legal regulations (e.g. when the aforementioned case pertains to the request for exercising rights you are entitled to in accordance with the GDPR).
  • We process your data for the purposes of analysing case reported and improvement of the quality of service of persons contacting us. We act on the ground of our legitimate interest, involving the possibility to ensure the highest possible quality of service to persons contacting us (legal ground – point (f) of Article 6(1) of the GDPR);
  • We process your data for the purposes of the establishment, exercise or defence of legal claims. The ground for the processing of your data is our legitimate interest, involving the potential defence or exercise of legal claims (point (f) of Article 6(1) of the GDPR).

How long will we keep your data for?
We will keep your data for the period specified below:

  • for the purposes of the processing of the case reported by you, as well as the establishment, exercise or defence of legal claims – for the period of the processing of the case, and thereafter – until the expiry of the claim limitation period;
  • for the period of analysis and improvement of the quality of service of persons contacting up – until you make an effective objection.

To whom are your personal data transferred?
In addition to entities listed in point 7.1 above, your data can also be transferred to entities managing external applications used for the purposes of service of persons contacting us, e.g. chatbot, live chat, and operators of social media.


Processing of data for marketing purposes
If you are interested in receiving marketing messages via a selected communication channel, your personal data can also be processed for marketing purposes, including profiling. Related information is presented in point 8 “Marketing” [link].

 

7.10. Candidate for work
Information on the processing of personal data of candidates for work is available at:
https://www.benefitsystems.pl/o-nas/kariera/obowiazek-informacyjny-dla-kandydata/.

 

8. Marketing
8.1. General information


The manner of the processing of personal data for marketing purposes depends on the circumstances, such as our relationship with you (e.g. whether you registered on our website or in mobile application or just view our website) and on consent you potentially granted.


Our marketing activities can include direct marketing (involving presentation of an offer or advertising via a communication channel, such as e.g. e-mail or telephone), carrying out analyses and statistics for marketing purposes and surveys of satisfaction with services via the communication channel selected by you. For the purposes of direct marketing, we also carry out profiling.


8.2. Online marketing
If you visit our website or use our mobile applications, we process personal data (first of all IP address, cookie identifiers, information on the location) for marketing purposes, including for the purpose of direct marketing, including profiling, in the following instances:

  • If you grant your consent to saving the cookies or similar technologies used by us for marketing purposes on your device, we will record what content you viewed on our websites or in our mobile application. We will use this information to display advertisements or offers adjusted to your potential interests identified based on the content you viewed. For instance, if you viewed pages pertaining to the MultiSport swimming pool packages, we will want to show you a swimming pool advertisement.

Additionally, if you are a registered user of our website or mobile application and log in to your account, we will be able to associate with you the collected information on the content viewed by you and use it for the purposes of profiling in order to better adjust our marketing communication and offers.

  • If you grant your consent to use information on the location of your device (e.g. smartphone) for marketing purposes, we will be able to present the advertisement or offer adjusted to your location. For instance, we will be able to present the invitation to a celebration of the opening of our new fitness club nearby.

Additionally, if you are a registered user of our website or mobile application and log in to your account, we will be able to associate with you the information on the location and use it for the purposes of profiling in order to better adjust our marketing communication and offers.


The ground for the processing of your personal data is our legitimate interest (point (f) of Article 6(1) of the GDPR), involving presentation of adjusted advertisements and offers in relation to your consent to use cookies or similar technologies or – in the particular case – in relation to your consent to using information on your location for marketing purposes.

  • For the purposes of carrying out analyses and statistics for marketing purposes and surveys of satisfaction with our services via the communication channel selected by you.

The ground for the processing is our legitimate interest (point (f) of Article 6(1) of the GDPR), involving the improvement of the quality of user service and development of products and services offered by us.

More information on cookies is available in “Policy on cookies and other similar technologies”.

 


8.3. Marketing communication via the selected communication channel (e.g. e-mail, SMS/MMS, telephone, chatbot)

8.3.1. User of the MultiSport Card, user of the MultiLife Programme, client of the Fitness Club or a user registered on our website or in mobile application


If you are a user of the MultiSport Card, user of the MultiLife Programme, client of the Fitness Club or a user registered on our website or in mobile application, your personal data provided to us (e.g. in the registration form or in the contract) or that we collect in relation to your activities in the MultiSport Programme, MultiLife Programme, based on the Fitness Club card, on the website or in the mobile application, will be processed for marketing purposes, including for the purpose of direct marketing, including profiling, in the following instances:

  • If you grant voluntary consent to using the particular communication channel (e.g. e-mail, SMS/MMS, telephone) for the purposes of the provision of marketing content to you. Our marketing activities will include providing you with information about promotions, special offers and other marketing content, as well as sending inquiries and surveys of satisfaction with services via the communication channel selected by you. The content provided can be adjusted to your potential interest and preferences based on profiling.

Your consent to marketing communication can refer to (depending on your decision):

  • our own products and services as well as products and services developed jointly with business partners of Benefit Systems that are offered to our users and clients as additional benefits (e.g. dietician, trainer, educational and development services);
  • products or services of third parties, including companies of the Benefit Systems Group. The list of third parties is available here,

The ground for the processing of your personal data is our legitimate interest (point (f) of Article 6(1) of the GDPR), involving presentation of marketing content, including the content adjusted to you based on profiling, in relation to your consent to the selected communication channel to this end.


You can withdraw your consent to marketing communication at any time. To this end, you can contact as specified in point 6 above. Withdrawal of the consent shall not affect the lawfulness of our activities based on consent before its withdrawal.

  • For the purposes of carrying out analyses and statistics for marketing purposes and surveys of satisfaction with our services via the communication channel selected by you.

The ground for the processing is our legitimate interest (point (f) of Article 6(1) of the GDPR), involving the improvement of the quality of user service and development of products and services offered by us.


8.3.2. Person who is not our user or client
If you are not our user or client, but you grant voluntary consent to using the selected communication channel (e.g. e-mail, SMS/MMS, telephone) for the purposes of the provision of marketing content, e.g. when you contact us using the contact form and grant consent to receiving marketing messages to your e-mail, our marketing activities, including direct marketing, will include providing you with information about promotions, special offers and other marketing content, as well as sending inquiries and surveys of satisfaction with services via the communication channel selected by you. The content provided can be adjusted to your potential interest and preferences based on profiling.


Your consent to marketing communication can refer to (depending on your decision):

  • our own products and services as well as products and services developed jointly with business partners of Benefit Systems that are offered to you as additional benefits (e.g. dietician, trainer, educational and development services);
  • products or services of third parties, including companies of the Benefit Systems Group. The list of third parties is available here.

The ground for the processing of your personal data is our legitimate interest (point (f) of Article 6(1) of the GDPR), involving presentation of marketing content, including the content adjusted to you based on profiling, in relation to your consent to the selected communication channel to this end.


You can withdraw your consent to marketing communication at any time. To this end, you can contact as specified in point 6 of the Policy. Withdrawal of the consent shall not affect the lawfulness of our activities based on consent before its withdrawal.


We will also process your personal data for the purposes of carrying out analyses and statistics for marketing purposes and surveys of satisfaction with our services via the communication channel selected by you.


The ground for the processing is our legitimate interest (point (f) of Article 6(1) of the GDPR), involving the improvement of the quality of our service and development of products and services offered by us.


8.3.3. Party to a contract concluded with Benefit Systems or a representative or a contact person of an entity being a party to the contract concluded with Benefit Systems, e.g. representative of the Client, Partner


If you are a party to a contract concluded with Benefit Systems or a representative or a contact person of an entity being a party to the contract concluded with Benefit Systems, e.g. representative of the Client, Partner, you can grant voluntary consent to the processing of your data for marketing purposes, including direct marketing, and to using the selected communication channel (e.g. e-mail, SMS/MMS, telephone) for the purposes of the provision of marketing content. In such the case, your personal data disclosed to us (e.g. in the inquiry form or in the contract) will be processed for the following marketing purposes:

  • providing you with marketing content pertaining to own products and services of Benefit Systems as well as products and services developed jointly with business partners of Benefit Systems that are offered to you as additional benefits (e.g. dietician, trainer, educational and development services), as well as for the purposes of carrying out marketing analyses and statistics and surveys of satisfaction with services, and profiling, i.e. using data pertaining to your interests in order to provide you with adjusted offers and content;
  • providing you with marketing content pertaining to products and services of third parties, including companies of the Benefit Systems Group, as well as for the purposes of carrying out marketing analyses and statistics and surveys of satisfaction with services, and profiling, i.e. using data pertaining to your interests in order to provide you with adjusted offers and content. The list of third parties is available here.

The processing is based on your consent (point (a) of Article 6(1) of the GDPR).


8.4. What is profiling for marketing purposes?
The processing of your personal data for the purposes of direct marketing involves profiling.


Profiling means that by automated processing of your data we will draw conclusions about your potential expectations, interests and preferences. As a result, we will be able to better adjust our products, offers and advertisements. As part of the profiling process, we may also combine information you provide when using various products and services, e.g. the information you provide when visiting our website as a registered user, using the services of our Fitness Club as a user of the club card or contacting us via the chatbot.


Various data are used for the purposes of profiling:

  • data related to using the MultiSport Card, MultiLife Programme or Fitness Club card, Wesolandia (e.g. about the size of the employer, who enabled you to use the MultiSport Card/MultiLife Programme, size of the town, where you use the card/programme, use of sport facilities, use of services, types of classes selected by you, package used by you). Statistical data related to the same information are also taken into account in the profiling process;
  • data provided by you in relation to joining the MultiSport Programme or the MultiLife Programme, or purchase of the Fitness Club card (e.g. your gender, age and city where you live) or in relation to registration on our website or in the mobile application;
  • information collected using marketing cookies or similar technologies that enable us to understand the content you view on our websites or in our applications (provided that you agree to saving such cookies on your device);
  • information on the location of your device (e.g. smartphone) if you grant your consent to using this information for marketing purposes.

Tools provided by specialised third parties are used for the purposes of profiling. We endeavour to ensure that profiling generates tangible benefits to you, such as presentation of offers, promotions and advertisements you may consider interesting. In this way we would like to avoid presentation of content that is inadequate for you or that you might consider unattractive. For instance, if we conclude that you are a woman living in a medium-sized city, who attends dance classes on a regular basis as part of the MultiSport Programme, we will know that probably you are not interested in martial art classes in another distant city.


In relation to profiling, you will not be subject to a decision based solely on automated processing of your information, which would produce legal effects concerning you or similarly significantly affect you.

 


8.5. Our legitimate interest vs. your interests, rights and freedoms


Because the processing of personal data for marketing purposes, including profiling, takes place on the ground of our legitimate interest (point (f) of Article 6(1) of the GDPR), we have assessed whether your interests, rights and freedoms (e.g. right to privacy) do not override our legitimate interests. We concluded that we can process your personal data for marketing purposes on the ground of our legitimate interest, because:

  • we process your personal data for marketing purposes only when we conclude that you can reasonably expect such processing (e.g. you are a user of the MultiSport card or the MultiLife Programme, or Fitness Club card, you are registered on our website or in the application, you granted your consent to receiving marketing messages by e-mail);
  • individual marketing messages (e.g. by e-mail, SMS/MMS, telephone) are sent to you only upon your consent;
  • we enable you to object to the processing of your personal data for the purposes of direct marketing, and inform you about this right;
  • marketing messages pertaining to products or services of third parties unrelated to Benefit Systems are sent to you only if you grant separate consent thereto;
  • we believe that profiling for marketing purposes does not excessively interfere with your privacy. We focus on what products or services offered by us could be interesting to you. We do not follow your activities on external websites. Based on profiling, we do not take decisions affecting you, which would produce legal effects (e.g. refusal to conclude a contract) or similarly significantly affect you;
  • we believe that offers and advertisements provided to you based on profiling can be considered interesting. We do not want to provide you with content that you might consider unattractive;
  • we do not use data that are subject to special protection, e.g. data pertaining to the health status, for marketing purposes including profiling;
  • we do not intentionally process personal of children for marketing purposes;
  • we use technical and organisational measures that appropriately protect your personal data.

 

8.6. How long will we process your personal data for marketing purposes for?
The period of keeping your personal data for marketing purposes will depend on the circumstances.

  • If we process your personal data for marketing purposes on the ground of our legitimate interest – until the objection is made;
  • If we process your personal data for marketing purposes based on your consent – until the consent is withdrawn.

 

8.7. Objection pertaining to direct marketing


If you do not want us to process your personal data for the purposes of direct marketing, including profiling for the purposes of direct marketing, you can make the objection. The objection can be made at any time and not justification is required in relation thereto. If you make such an objection, your personal data will not be processed by us for the purposes of direct marketing any longer. In order to make the objection, you can contact as specified in point 6 of the Policy.

 

 

9. Rights of a data subject


You have the following rights related to the processing of your personal data:

 

  • Right of access to your data – you have the right of access to personal data concerning you that we process, and to obtain information in this respect from us; you also have the right to receive from us a copy of the personal data concerning you that we process.
  • Right to request rectification (correction) of your personal data – you can update personal data provided to us or request their rectification, where the data are incorrect. Depending on the purpose of the processing, corrections can be made in accordance with the rules of the service used by you or by contacting us in accordance with point 6 of this Policy.
  • Right to withdraw you consent to the processing of personal data – if we process your personal data based on consent granted by you, you have the right to withdraw this consent at any time. However, please remembers that this would not affect the lawfulness of processing based on consent before its withdrawal. The consent to the processing of personal data can be withdrawn, e.g. by contacting us as specified in point 6 of the Policy.
  • Right to object to processing of personal data – you have the right to object to processing of your personal data, where the processing is based on a legitimate interest (point (f) of Article 6(1) of the GDPR), and the objection is justified by your particular situation.

In the case of the processing of data for the purposes of direct marketing, including profiling for the purposes of direct marketing, the objection to such processing can be made at any time and does not require any justification. If you make such an objection, your personal data will not be processed by us for the purposes of direct marketing any longer. In order to make the objection, you can contact as specified in point 6 of the Policy.

  • Right to restriction of processing of your personal data – you have the right to restriction of the processing of your personal data, when: (i) you contest the accuracy of these personal data (for a period enabling us to verify the accuracy of these data); (2) the processing is unlawful and you oppose the erasure of your data and requests the restriction of their use instead; (3) we no longer need your personal data for our purposes, but they are required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to processing of your data pending the confirmation of the effectiveness of this objection. In such the case, we will restrict the processing of your data only to their storage, unless the processing is necessary for the establishment, exercise or defence of potential legal claims, or to protect third parties’ rights, or takes place upon your consent.

 

  • Right to personal data portability – in relation to the processing of your data based on your consent or a contract by automated means (e.g. using computers/in IT systems), you have the right to receive from us personal data that you provided to us, in a structured, commonly used and machine-readable format (e.g. on a computer). You can transmit these data to another controller or request us to transmit your data to another controller, but we will do it only where technically feasible.
  • Right to request erasure of your personal data – you can request us to erase your personal data in the following instances: (1) your data are no longer necessary in relation to the purposes for which they were processed; (2) you withdraw consent on which the processing is based, and there is no other legal ground for the processing; (3) you effectively object to processing; (4) your personal data have been unlawfully processed; (5) your data have to be erased for compliance with an obligation arising from legal regulations. In the aforementioned instances, your data will be erased, unless in the particular case we refer to one of the exceptions provided for in the GDPR (e.g. further processing of your data is necessary for the establishment, exercise or defence of potential legal claims).

In order to exercise the aforementioned rights, please contact us or our Data Protection Officer, as specified in point 6 of the Policy. Your request will be processed without undue delay, and in any case no later than without one month of its receipt. If this period has to be extended, we will notify you both of this extension and its reasons.

  • Right to lodge a complaint with a supervisory authority – if you believe that the processing of your personal data by us breaches legal regulations (GDPR), you can lodge a complaint with a supervisory authority in charge of the protection of personal data, in particular in the member state of your habitual residence, place of work or place of the alleged infringement; in Poland the supervisory authority is the President of the Office for the Protection of Personal Data.

 

 

10. Amendments to the Privacy Policy


We will review and update this Policy on a regular basis in connection with amendments to legal regulations and any new measures we may take in relation to your personal data.

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