Privacy policy
DATA PROTECTION NOTICE
1. Introduction
The purpose of this Data Protection Notice is to provide a transparent overview of the data processing practices related to the central operation of the MozgásKlinika nationwide franchise network.
MozgásKlinika operates as a franchise-based healthcare provider network. The central functions of the network are performed by Physio Consulting Limited Liability Company (hereinafter: Franchise Center).
The Franchise Center does not provide healthcare services and does not operate clinics. Its responsibilities include the coordination of network operations, quality assurance, maintenance of professional methodology, brand management, and the related administrative and communication activities.
Healthcare services are always provided by the individual MozgásKlinika clinics, which are operated by independent franchise partners (franchisees) acting as separate legal entities.
2. Data Controllers and Their Roles
2.1. Franchise Center as Data Controller
Data Controller:
Physio Consulting Kft.
Registered office: 1105 Budapest, Halom köz 3c. ground floor 3
Company registration number: 01-09-414399
E-mail: info@mozgasklinika.hu
The Franchise Center acts as a data controller with regard to data processing related to network operations, website operation, and central communication activities.
2.2. Joint Data Controllership with Franchisees
Due to the franchise-based operation of MozgásKlinika, certain data processing activities qualify as joint data controllership between the Franchise Center and the clinic operator concerned, in accordance with Article 26 of the GDPR.
Joint data processing typically covers the following areas:
– network-level quality assurance and professional audits,
– operation of a unified professional and documentation framework,
– network-level administrative and communication processes,
– maintenance of brand and service quality standards.
Joint data controllership does not imply that the Franchise Center provides healthcare services or takes decision-making responsibility in individual patient care or treatment processes.
2.3. Independent Data Controllership
Data processing related to healthcare services – in particular health data and medical documentation – falls primarily under the responsibility of the clinic operator concerned, acting as an independent data controller.
3. Professional Audit and Supervision
As part of the MozgásKlinika franchise system, the Franchise Center performs network-level professional audit and supervisory activities.
The purpose of professional audits includes:
– reviewing the adequacy of documentation and administrative frameworks,
– ensuring network-level service quality,
monitoring compliance with unified professional protocols and methodologies,
– supporting continuous professional development.
Professional audits constitute quality assurance and system supervision activities and do not qualify as healthcare services. They do not involve independent decision-making regarding individual patient care, therapeutic interventions, or treatment modifications.
Professional leaders, auditors, and supervisory personnel delegated by the Franchise Center ensure the consistency and professional standards of network operations and do not assume direct healthcare responsibility.
All professional decisions related to healthcare services and the resulting liability remain with the clinic operator providing the care.
4. Categories of Data Processed by the Franchise Center
4.1. Website Use
When visiting the website mozgasklinika.hu, the following data may be processed:
– technical data (IP address, browser type, device information),
– cookies,
– statistical and analytical data.
The purpose of data processing:
– operation and development of the website,
– preparation of visitor statistics,
– improvement of user experience.
4.2. Contact Requests
When contacting the Franchise Center via the website, the personal data provided by the data subject (name, e-mail address, message content) are processed.
The purpose of data processing:
– responding to inquiries,
– providing franchise- and network-related information.
4.3. Professional and Network Communication
The Franchise Center may send occasional professional, operational, or network-related information to data subjects.
Such communication may include in particular:
– information related to network operations and service frameworks,
– professional guidelines, methodological and educational content,
– transparency of quality assurance and documentation systems,
– support for consistent operation within the franchise network.
This type of communication does not constitute direct marketing or sales communication and does not contain specific offers, pricing information, discounts, or calls to use services.
The legal basis for this data processing is the legitimate interest of the Franchise Center in maintaining the quality and transparency of network operations.
Data subjects have the right to object to such communication at any time.
Marketing or service-related communications may only be sent based on the prior, explicit consent of the data subject.
4.4. Centralised Communication with Data Subjects
Due to the operation of the MozgásKlinika franchise network, the Franchise Centre is entitled, within the framework of joint controllership pursuant to Article 26 of the GDPR, to maintain direct communication with data subjects.
The purpose of such communication includes, in particular:
– providing information related to the operation of the franchise network, system use and quality assurance,
– sharing professional and educational content,
– ensuring the uniform operation and transparency of the franchise network.
Communication conducted by the Franchise Centre does not constitute the provision of healthcare services, does not affect professional decisions related to individual patient care, and does not qualify as direct business solicitation or marketing communication.
The data subject shall have the right to object to the communication described in this section at any time.
5. Data Processors
In order to achieve its data processing purposes, the Franchise Center may engage data processors, including in particular:
– hosting and server service providers,
– website operation and maintenance providers,
– analytics and statistical systems,
– communication and newsletter systems (e.g. ActiveCampaign),
– online form and data collection tools (e.g. Typeform),
– automation and system integration services (e.g. Make.com),
– online appointment booking systems (e.g. Salonic).
Data processors act solely on the instructions of the Franchise Center and under appropriate data protection and security guarantees.
If a data processor is located outside the European Union, data transfers take place based on appropriate safeguards approved by the European Commission, in particular Standard Contractual Clauses (SCCs).
Due to the nature of appointment booking systems, personal data provided by data subjects are transferred to the clinic operator concerned, who acts as an independent data controller with respect to such data processing.
6. Data Transfers
The Franchise Center transfers personal data to third parties only:
– in order to comply with a legal obligation, or
– based on the explicit consent of the data subject.
The Franchise Center does not independently process or transfer health data.
7. Rights of Data Subjects
Data subjects have the right to:
– request information about the processing of their personal data,
– request access to their data,
– request rectification or erasure,
– request restriction of processing,
– object to data processing.
The exercise of rights depends on the nature of the specific data processing. Where necessary, the Franchise Center forwards requests to the competent clinic operator.
8. Data Security
The Franchise Center implements appropriate technical and organizational measures to ensure the security of the processed data, in particular to protect against unauthorized access, alteration, or destruction.
9. Final Provisions
The Franchise Center reserves the right to amend this Data Protection Notice. Any amendments will be published on the website.
Complaints related to data processing may be submitted to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH).