PRIVACY NOTICE ON VIDEO SURVEILLANCE

 

Through this Privacy Notice we would like to provide you with details about the processing of your personal data in the context of using the video surveillance system in our locations.

We recommend that you read this Privacy Notice together with the Privacy Policy, in order to obtain as much information as possible on how we protect your personal data.

WHAT ARE THE CATEGORIES OF PERSONAL DATA THAT WE PROCESS?

The use of closed-circuit television (CCTV) involves processing your image or other personal data that can be seen in the recordings and which may lead directly or indirectly to your identification.

WHAT ARE THE VIDEO SURVEILLANCE AREAS?

The CCTV system includes the headquarters in Calea Bucuresti 1k, Baloteşti, Ilfov County.

We monitor by video means the following locations:

  • Access and transit areas, interior and exterior of buildings;
  • Parking, barrier area, production and storage areas, technical areas;
  • Customer/visitor spaces such as receptions, cash registers, restaurant and bar areas, swimming pools, access corridors, crossing points, etc.;
  • Spaces intended for employees/collaborators/partners;
  • Restricted areas;
  • Outdoor areas where there are tourist facilities (playgrounds, parks, beaches, etc.);
  • Places of handling and storage documents and media;
  • Storage spaces for Therme’s goods and values.

The location of surveillance cameras has been carefully reviewed to ensure that monitoring of areas that are not of interest to the intended purpose is limited as much as possible.

No video surveillance is placed in areas where there is a high expectations of privacy, such as personal offices, toilets and other similar locations.

There is no video surveillance of public spaces outside the property.

The existence of video surveillance cameras is marked in each area of the Therme complex, by using information panels or representative pictograms placed in visible areas, mainly at entrances, rotating doors, turnstiles or other strategic points.

WHY DO WE PROCESS THIS PERSONAL DATA?

The video surveillance system complements the security and protection measures implemented based on the risk assessment regarding the security of the Therme complex.

We use the video surveillance system based on the fulfillment of our legal obligations regarding the protection of objectives, goods, values and protection of individuals and on our legitimate interest for purposes such as:

  • Protecting Therme property, goods and values by preventing, combating and researching unauthorized physical access;
  • Making vehicle access control measures more efficient at barrier crossings;
  • Preventing, combating and investigating incidents;
  • Preventing and combating crime;
  • Ensuring health and safety of people;
  • Protection of human life, physical integrity and personal freedom;
  • Protection of trade and valuables;
  • Protection of commercial and financial interests;
  • Preventing and investigating unauthorized access to IT infrastructure or business information, protecting documents and confidential information;
  • Investigation and legal settlement of complaints;
  • Ensuring health and safety of people that use sports facilities within the complex as well as of the personnel operating them, by ensuring that the hygienic and sanitary requirements regarding the functionality, maintenance and supervision of swimming pools and their harmonization with the legal regulations are complied;
  • Defending a right in court;
  • Recovery of losses.

We have conducted a Data Protection Impact Assessment for video image processing in order to identify and mitigate the risks associated with data processing so that our legitimate interests do not override your rights and freedoms.

WHO ELSE HAS ACCESS TO YOUR PERSONAL DATA?

Personal data may also be accessed by other third parties to the extent that this is reasonably necessary in accordance with the purposes set out in this notice.

For details, please see the dedicated section of the Privacy Policy.

HOW DO WE MANAGE INTERNATIONAL DATA TRANSFER?

For this processing activity we do not transfer your data outside the country.

The video materials are processed and stored on servers located in Therme Bucuresti complex.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Usually, video images are kept for up to 30 days.

To the extent that certain situations require that video footage be kept for a longer period (depending on the time it takes to further investigate a security incident, for the purpose of defending a right in court, for the purpose of fulfilling a legal obligation or a well-founded legitimate interest, the retention period may be extended in accordance with the purposes pursued.

WHAT ARE YOUR RIGHTS?

For the purposes of using your personal data for the purposes aforementioned, you shall have the following rights:

  • Right to be informed;
  • Right of access;
  • Right to rectification;
  • Right to erasure, under the conditions stipulated by law;
  • Right to restriction of processing;
  • Right to data portability to another controller, under the conditions stipulated by law;
  • Right to object to the processing of your personal data;
  • Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you or similarly affects you to a significant extent, with the exceptions set out in data protection laws;
  • Right to lodge a complaint with a supervisory authority.

UPDATING THE PRIVACY NOTICE

The information presented in this Privacy notice will be reviewed periodically to reflect any changes in current processing activities.

Please visit this page periodically to make sure you always have up-to-date information.

However, if we intend to significantly change the way we use your personal data, we will notify you in advance.

Last update: April 2022