Privacy Policy (last update: 01-06-2018)


Privacy Policy
High Five Health Promotion considers the protection of your personal data very important. In this Privacy policy, we want to provide clear and transparent information about how we handle personal data. We take the utmost precaution to safeguard your privacy, and we therefore handle your personal data with extreme care. In all cases, High Five Health Promotion complies with the applicable legislation and regulations, including the General Data Protection Act (GDPR). This means in any case that:
- We process your personal data in accordance with the purpose for which they were given. These purposes and type of personal data are described in this Privacy policy;
- The processing of your personal data is limited to only the data required for the purpose for which it is being used;
- We ask your express consent if we need your personal data for processing;
- We have taken the appropriate technical and organizational measures to ensure the security of your personal data is guaranteed;
- No personal data will be passed on to third parties, unless this is necessary for carrying out the purposes for which they were given;
- We are aware of your rights regarding your personal data, wish to make your aware of that fact, and that we will respect them.

As High Five Health Promotion, we are responsible for processing your personal data. If you have any questions after having read this Privacy Policy, or if you have questions in general or wish to contact us, please use the contact information provided at the bottom of this document.

Processing personal data
High Five Health Promotion processes personal data of members for the following purpose(s):
- Administrative purposes;
- Communications about instructions, invitations and information regarding (changes in) the provision of our services;
- Performance or outsourcing of an instruction.
- Improving our services and invitations for participating in satisfaction surveys
- Provision of information through news publicity (only with your consent, of course).

The basis for this personal data is:
The instruction agreed on, that being, taking out a membership subscription or using services;

For the aforementioned purpose(s) High Five Health Promotion may collect and/or ask you to provide the following personal data:
- First name and surname;
- Address;
- Gender;
- Date or Birth;
- Telephone number;
- Email address;
- Payment details;
- Data for the intake (including medical information);
- Information regarding your membership;
- Name of employer and where necessary, your department, if you have joined through your employer;
-Email communication between you and us.

Retention of personal data
High Five Health Promotion will not retain the collected personal data longer than strictly necessary or provided for by law in order to fulfil the purposes for which the data has been collected.
We adhere to the following retention times per purpose:
- Your data will be retained up to six months after termination of membership, following which all your data is anonymized in our portal.
- Data pertaining to invoicing is retained in a local database up to eight years after termination of membership.

Processing of special personal data
High Five Health Promotion processes the following special and/or sensitive personal data, when you use our services and/or because you provided us with this data:
- test data, including medical information such as your blood pressure;
- answers to medical questionnaires;
- data about training goals;
- data provided by wearables.
High Five Health Promotion is particularly careful when dealing with this personal data and processes it only when strictly necessary for carrying out our services. This data is only given to others within High Five Health Promotion if required for the performance of their work activities. This personal data will be deleted within six months after termination of your membership.

Provision of data to third parties
The data you give us may be provided to third parties if this is necessary for the performance of the objectives described above.
For example, we use a third party for:
- Handling the internet environment and software;
- Providing the chosen service and invitations;
- Carrying out our administration, including (financial) administration;
- Providing our newsletters (only with your consent, of course).

If a part of our service provision is carried out by a third party, your name, email address and telephone number will be provided to this third party.

If you make use of our services through your employer, whereby membership costs are paid through your employer or via your salary, then the employer periodically receives a list with your name, personnel number, and the start and end dates of your membership subscription.

We never give other parties your personal data unless we have entered into a processing agreement with them. Naturally, we make the necessary agreements with these processing parties to guarantee the security of your personal data. Furthermore, we will not provide other parties with the data you have given us, unless this is required and permitted by law. One example of this is if the police request personal or other data from us in the context of an investigation. In such a case, we must cooperate and are obliged to provide them with this information. Furthermore, we may share personal data with third parties if you give us written consent to do so.

Within the EU
Personal data will be processed within the European Union or in secure third countries.

Minors
We solely process the personal data of minors (persons younger than 16 years of age) if written consent has been provided by a parent, caregiver or legal representative.

Retention period
High Five Health Promotion retains personal data no longer than strictly necessary for the purpose for which they were provided or when required pursuant to the law.

Security
High Five Health Promotion takes the protection of your data seriously and takes appropriate measures to prevent the misuse, loss, unauthorized access, unwanted publication and unauthorized changes to your data. High Five Health Promotion’s website uses a reliable SSL Certificate to ensure your personal data does not fall into the wrong hands. If you have the impression that your data is not properly protected, if there are any indications of misuse, or if you wish more information about the security of the data collected by High Five Health Promotion, please contact High Five Health Promotion.

Cookies or similar techniques used
High Five Health Promotion solely uses technical and functional cookies. We also use analytical cookies that do not infringe your privacy. A cookie is a small text file that is stored on your computer, tablet or smartphone upon your first visit to this website. The cookies we use are necessary for the technical operation of our website and for your ease of use. They ensure the website works properly; they remember your preferred settings, for example. We also use them to optimize our website.
Our cookies cannot be used to identify persons. You can opt out of cookies use by setting your Internet browser so that it no longer saves cookies. In addition, you can also delete any information that was saved earlier in your browser’s settings.
You automatically agree to the use of cookies by making use of our website.

Rights pertaining to your data
You are entitled to inspect, rectify or delete the personal data we have received from you. You may also object to the processing of your personal data, or a part thereof, by us or one of our processors. You are also entitled to have us transfer the data you have provided to us, either to yourself or directly to another party, on your instructions. We may ask you to provide proof of identity before we can comply with the aforementioned requests. You can direct your request for inspection, modification or deletion to dataprotection@highfive.fit

Should we process your personal data based on the consent you have given, you are always entitled to withdraw this consent.

Complaints or questions
Should you have a complaint or question about the processing of your personal data, we request that you contact us immediately. Should we not come to a mutually satisfactory resolution, we would regret this very much. You are always entitled to submit a complaint to the Personal Data Authority, the regulatory authority for the protection of privacy.

Questions
If you have any questions or comments with regard to our Privacy Statement please contact us!

Changes
High Five Health Promotion reserves the right to change the content of this Privacy Policy at any time.

Data Protection Officer
High Five Health Promotion has appointed Bjorn Vergers as our Data Protection Officer. He/she is available under the following contact information:
Bjorn Vergers
Manager Quality, Health and Safety and Environment, Data Protection Officer
Schinkeldijkje 18
1432CE Aalsmeer
dataprotection@highfive.fit
+31 20 4261222

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