PRIVACY POLICY

 

Progym, Sole Proprietorship for Sports Instruction and Training (“Progym”) is committed to protecting the privacy and security of the personal data of its clients, users, members, business partners, employees and other individuals whose personal data it processes in the course of its business activities.

The protection of personal data is a fundamental right of every individual. Progym implements appropriate organizational and technical measures to ensure that personal data is processed lawfully, fairly and transparently, in accordance with applicable legislation, including Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR) and the Croatian Act on the Implementation of the General Data Protection Regulation.

This Privacy Policy explains what personal data Progym collects, for what purposes it is processed, the legal basis for processing, how long the data is retained, and what rights individuals have regarding their personal data.

 

1. Data Controller

Progym, Sole Proprietorship for Sports Instruction and Training
Owner: Adrian Bečić
Hektorovićeva ulica 38
21210 Solin, Croatia
OIB: 97962114641

E-mail: adrianbecic@gmail.com

For the purposes of the GDPR, Progym is the data controller responsible for the processing of personal data collected and processed in connection with its business activities.

 

2. Principles of Personal Data Processing

Progym processes personal data in accordance with the following principles:

• lawfulness, fairness and transparency

• purpose limitation

• data minimization

• accuracy

• storage limitation

• integrity and confidentiality

• accountability.

Personal data is collected and processed only to the extent necessary for a specific and legitimate purpose.

 

3. How We Collect Personal Data

Progym may collect personal data:

• directly from users when they register or enroll in a training program

• through telephone communication

• through e-mail communication

• through contact forms on the website

• through social media when a user contacts Progym

• through the website www.progym.hr

• through cookies and similar technologies, in accordance with the Cookie Policy.

 

4. Types of Personal Data We Process

Depending on the service and the nature of the interaction, Progym may process the following categories of personal data.

Identification Data

• first and last name

• date of birth, when required for a particular program or age group.

 

Contact Data

• telephone number

• e-mail address.

 

Training-Related Data

• selected training program

• training schedule and appointments

• information necessary for organizing and conducting training

• training attendance records

• training progress and performance results.

 

Information Relevant to Training Safety

Users may voluntarily provide information regarding health-related limitations, injuries or other circumstances that may be relevant to the safe performance of physical activity.

Such information is processed only when necessary to appropriately adapt training and in accordance with applicable data protection legislation.

 

5. Personal Data of Children and Minors

Progym provides training programs intended for children and young athletes.

When processing personal data relating to children or minors, Progym pays particular attention to protecting their privacy and personal data.

Personal data may be collected from a parent or legal guardian when necessary for enrollment, organization and provision of training services or where consent is required.

Photography or video recording of children and publication of such material on the Progym website, social media or promotional materials will only take place where there is an appropriate legal basis and, where required, prior consent of the parent or legal guardian.

 

6. Purposes of Processing Personal Data

Personal data may be processed for the following purposes:

• registration and enrollment in training programs

• organization and provision of training services

• communication with users and clients

• scheduling and attendance management

• adapting training to individual needs

• monitoring training progress

• processing payments and issuing invoices

• fulfilling legal and accounting obligations

• responding to inquiries

• protecting the safety of users and property

• improving the quality of Progym's services

• sending promotional and informational communications where there is an appropriate legal basis

• publishing photographs and video recordings where appropriate consent has been provided

• protecting and exercising Progym's legal rights and interests.

 

7. Legal Bases for Processing

Depending on the purpose of processing, Progym processes personal data on the basis of one or more of the following legal grounds:

• Article 6(1)(b) GDPR – processing is necessary for the performance of a contract or for taking steps at the request of the data subject prior to entering into a contract

• Article 6(1)(c) GDPR – processing is necessary for compliance with a legal obligation

• Article 6(1)(f) GDPR – processing is necessary for the purposes of the legitimate interests pursued by Progym, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject

• Article 6(1)(a) GDPR – processing is based on the consent of the data subject where consent is required.

Where special categories of personal data, such as health-related information, are processed, Progym will ensure that an appropriate legal basis under Article 9 of the GDPR is applicable.

 

8. Photography and Video Recording

As part of training sessions, events and promotional activities, Progym may take photographs or make video recordings of users.

Photographs and video recordings may be used for:

• presenting Progym's activities

• promoting training programs and services

• publication on the Progym website

• publication on social media

• promotional materials.

Where consent is required as the legal basis for such processing, photographs and video recordings will only be published on the basis of appropriate consent.

Consent may be withdrawn at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

 

9. Data Processors

Progym may use external service providers who may process personal data on behalf of Progym.

These may include, for example:

• accounting service providers

• IT service providers

• website maintenance providers

• hosting providers

• e-mail service providers

• other service providers necessary for the operation of the business.

Progym will use appropriate service providers and, where required, regulate the processing of personal data through appropriate data processing agreements in accordance with the GDPR.

 

10. Security of Personal Data

Progym implements appropriate technical and organizational measures to protect personal data against:

• unauthorized access

• loss

• destruction

• unauthorized alteration

• unauthorized disclosure

• other unlawful processing.

Access to personal data is limited to persons who require such access to perform their duties.

 

11. Data Retention Periods

Personal data is retained only for as long as necessary to fulfill the purpose for which it was collected or for as long as required by applicable law.

The retention period depends on the type of data and the purpose of processing.

Type of dataRetention period

User data required for provision of servicesFor the duration of the business relationship and for as long as necessary thereafter

Training and attendance recordsFor the duration of the program and as long as necessary for administrative and legal purposes

Invoices and accounting documentationFor the periods required by applicable accounting and tax legislation

Job applicant dataUntil completion of the recruitment process, or longer where there is an appropriate legal basis

Data processed on the basis of consentUntil consent is withdrawn or the purpose of processing ends

Cookie-related dataIn accordance with the retention periods specified in the Cookie Policy

After the applicable retention period expires, personal data will be deleted, destroyed or anonymized, unless there is a legal obligation to retain it for a longer period.

 

12. Cookies

The website www.progym.hr may use cookies and similar technologies to ensure the proper functioning of the website, improve the user experience and, where applicable, analyze website usage and support marketing activities.

Cookies may include:

• strictly necessary cookies

• functional cookies

• analytical cookies

• marketing cookies.

Cookies that are not necessary for the proper functioning of the website will be used in accordance with applicable legislation and, where required, only with the user's consent.

More detailed information is available in the Cookie Policy published on the Progym website.

 

13. Data Subject Rights

Depending on the circumstances of the processing, individuals have the right to:

• request access to their personal data

• request correction of inaccurate or incomplete personal data

• request deletion of personal data where the applicable conditions are met

• request restriction of processing

• request data portability where the applicable conditions are met

• object to certain types of processing

• withdraw consent where processing is based on consent

• lodge a complaint with the competent supervisory authority.

The exercise of a particular right may be restricted where Progym has a legal obligation or another lawful basis requiring continued processing.

 

14. Exercising Your Rights

Requests concerning the exercise of data protection rights may be submitted by:

E-mail: adrianbecic@gmail.com

Progym will respond to a request without undue delay and, in any event, within one month of receiving the request, unless the GDPR permits an extension of this period.

For security and privacy reasons, Progym may request additional information necessary to verify the identity of the person submitting the request.

 

15. Right to Lodge a Complaint

If an individual believes that the processing of their personal data infringes the GDPR or other applicable data protection legislation, they have the right to lodge a complaint with the competent supervisory authority.

The competent supervisory authority in Croatia is:

Croatian Personal Data Protection Agency (AZOP)
Ulica Metela Ožegovića 16
10000 Zagreb
Croatia

Telephone: +385 (0)1 4609 000
E-mail: azop@azop.hr
Website: www.azop.hr

 

16. Personal Data Breaches

In the event of a personal data breach, Progym will take appropriate measures to identify, contain and mitigate the consequences of the breach.

Where required by the GDPR, Progym will notify the competent supervisory authority without undue delay and, where applicable, within 72 hours of becoming aware of the breach.

Where a personal data breach is likely to result in a high risk to the rights and freedoms of individuals, Progym will, where required by the GDPR, notify the affected individuals.

 

17. Changes to This Privacy Policy

Progym reserves the right to amend or update this Privacy Policy from time to time due to changes in its business activities, technology or applicable legislation.

The updated version of the Privacy Policy will be published on the Progym website.

Last updated: 28.08.2026