ESCAPE ROOM PRIVACY POLICY

The purpose of this document is to inform you how Locked Services Korlátolt Felelősségű Társaság
(hereinafter: “Locked Services” or “Controller”) processes your personal data in case you visit one of
the escape rooms operated by Locked Services.
In this privacy policy you will find information about why, on what the legal basis, and for how long
we process your personal data, and whom we transfer your personal data. We also inform you
about your rights that you have in relation with our data processing activities.
Please do read this Policy carefully and if you have any questions or inquiries related to the data
processing of Locked Services, do not hesitate to contact us at:
Locked Services Korlátolt Felelősségű Társaság
address: 1012 Budapest, Vérmező út 10-12.
e-mail: locked.hu@gmail.com
Contact person: Kozák Dániel
1. What do we do to protect your data?
Locked Services is committed to protecting your data, that is why we will do our best to process your
personal data in accordance with the law. Locked Services follows the following the principles during
data processing:
 We process personal data lawfully.
 We process personal data limited to its purpose, according to data minimization, for a limited
period of time.
 We protect your personal data.
 We help you exercise your rights related to data processing.
2. In what cases do we process your personal data?
2.1. If you make a reservation for an escape game or a teambuilding training
Why do we process your
personal data?

We process your data in order to fulfil your reservation (order) for the
requested escape game according to your request, and to keep in touch
with the most competent person related to the reservation.

What is the legal basis of the
processing?

If you have made the reservation as a private person in your own name,
Locked Services processes your personal data for the above mentioned
purpose, because data processing is necessary for performing the contract
in which you are a concerned party.
If you have made the reservation as a representative, your personal data
will be processed based on the legitimate interest of Locked Services, for
communicating with the most competent person related to the
performance of the concerned contract. Locked Services has made an
interest assessment test, which we provide for you upon your request.

Are you obliged to disclose
your data?

No, you are not obliged by law to provide your data. In case you do not
disclose your data, we will not be able to save your booking, we cannot
perform the contract.

Which categories of data we
process?

Your last name, first name, e-mail address, telephone number, coupon
code and reservation code.

How long we store the data? If the parties declared the contact person, your personal data will be stored
for 5 years from date of the game, as long as the data has to be stored as
required by the accounting / tax law.

To whom do we transfer
your data?

On the above purpose your data will be transmitted to our webpage
developer, Gábor Juhász (1148 Budapest, Mogyoródi út 68. B lh. 4 em. 15.),
individual entrepreneur, who has access to personal data as a data
processor.

2.2. If you are the cost bearer of the reservation
Why do we process your
personal data?

We process your personal data to fulfil our invoicing and accounting
obligations.

What is the legal basis of the
processing?

Locked Services processes your personal data for the above purpose to
fulfil its legal obligations prescribed by VAT Act.

Which categories of data we
process?

Your name, address (billing address), VAT number.

Are you obliged to disclose
your data?

According to VAT Act you must disclose your data , the mandatory content
of the invoice are determined by law.

How long we store the data? Your data will be stored until the data storage period specified in the

accounting / tax laws.

To whom do we transfer
your data?

For the above purpose your data will be transferred to the invoicing
software operator, KBOSS.hu Kft. (1031 Budapest, Záhony utca 7.), who has
access to personal data as a data processor.

2.3. If you sign a declaration of liability as a player
Why do we process your
personal data?

We process your data to limit the Company’s liability in relation with using
the escape rooms.

What is the legal basis of the
processing?

The legal basis of processing your data is our legitimate interest in order to
restrict the liability in relation with the use of the escape rooms. Locked
Services has made an interest assessment test, which we provide for you
upon your request.

Which categories of data we
process?

Your name, address, content of the declaration and signature

Are you obliged to disclose
your data?

No, you are not obliged by law to provide your data. If you do not provide
your data, we will not be able to let you into the escape room, so we will
not be able to fulfil the requested service.

How long we store the data? Your data will be stored for 5 years as of the date of the game, in case of

use until the final closing of the procedure.

To whom do we transfer
your data?

Your data will not be transferred to third parties.

2.4. If you are in an area monitored by CCTV
Why do we process your
personal data?

We process your data because Locked Services operates CCTV at the
locations of the escape rooms located at 1061 Budapest, Székely Mihály
utca 4-6. alagsor 1. and 1068 Budapest, Király utca 14. fszt. 5. for the
following reasons:
 the purpose of the CCTV outside the escape rooms is to protect
property (Locked Services’ assets and assets of the players and
other people, and to provide evidence to support the investigation
of the crimes committed against them)
 the purpose of the CCTV in the escape rooms is primarily to
provide direct assistance to players and it serves also personal and
property security reasons: examining possible accidents and
damage in the escape rooms, the use of recordings as evidence in
a possible procedure.

What is the legal basis of the
processing?

The legal basis of processing your data is our legitimate interest. Locked
Services’ legitimate interests are
 the protection of Locked Services’ assets and assets of the players
and other people, and to provide evidence when investigating
crimes committed against them,
 providing direct assistance to players,
 examining possible accidents and damage in the escape rooms
Locked Services has made an interest discretion test, which we provide for
you upon your request.

Which categories of data we
process?

For the above purposes we process images about you (photo/video)
How long we store the data? For the above purposes your personal data will be stored for 15 days from
the recording, and in case of use, until the final closing of the procedure.

To whom do we transfer
your data?

Your personal data will not be disclosed to third parties for the above
purposes, except for use.

2.5. If you use the selfie machine located at the escape room
Why do we process your
personal data?

We process your data so that you can make a photo about participating in
the game for your own purposes, and to forward it to an e-mail address
specified by you.

What is the legal basis of the
processing?

Your personal data will be processed based on your consent.

Are you obliged to disclose No, you are not obliged by law to provide your data. If you decide not to

your data? provide your personal data, you will not able to use the selfie machine

service.
Which categories of data we
process?

Photo (portrait), e-mail address

How long we store the data? Your data will be stored until you withdraw your consent, but not later

than 30 days.

To whom do we transfer
your data?

The selfie machine storage provider, dslrBooth (293 State Route 18 #123
East Brunswick, NJ 08816 USA) may have access to your personal data as
data processor, to whom the data is transferred based on a model
contract.

3. What are your rights in relation with data processing by Locked Services?
We do not charge a fee for answering questions about data processing or meeting the request.
However, if your request has no grounds and it is exaggerated (e.g. repetitive), we will have to charge
you an administrative fee of 20.000 HUF.
Please note that if you contact us with any questions or requests and we have doubts about your
identity, we may ask you for further information to confirm your identity.
We will answer to your request and questions in relation with the data processing within 1 month as
of the receipt of your request. If it’s not possible, we may prolong this period with further 1 month,
in which case you will be informed.
Access


You have the right to ask for information whether your personal data
is being processed. You can ask us about the purposes of processing,
what personal data is processed, who can receive your personal data
and how long we process it.

Rectification


In case your personal data is incorrect or incomplete, you can request
us to correct your inaccurate personal data and to complete your
incomplete personal data.
Please note that by reporting a change in your personal data, you
help Locked Services to keep always accurate data about you.

Restriction


You may request the restriction of processing of your personal data if
 you have contested the accuracy of such data, for a period
which is necessary for us to verify the accuracy of the data,
 the processing of the data is unlawful, but you do not want
your data to be deleted,
 we no longer need the data, but it is necessary for you for
the initiating, exercising or defencing your legal claims,
 you have objected to the processing, for the period in which
it was established that our legitimate interest overrides your
interests.

Objection


You object to the processing of your personal data any time if the
legal basis of the processing was the legitimate interest of Locked
Services. You can find information about it in the “What is the legal
basis for processing?” section of this notice.
If you object to data processing, we will try to convince you why data
processing is important for Locked Services and why it wouldn’t be
harmful to you.

Erasure


You can request us to delete your personal data in the below cases:
 the processing of your data is no longer necessary for the
purposes why we have collected or processed your data,
 you withdrew your consent and we have no other legal basis
for processing your data,
 you object to the processing and we have no other legal
ground for processing,
 we have unlawfully processed your personal data.

Withdrawal of
consent


In case the legal basis of the processing is your consent, you have the
right to withdraw your consent at any time. Please note that the
withdrawal of your consent does not affect the lawfulness of
processing before the withdrawal.
You can find information about in which case we base your data
processing on your consent in “What is the legal basis of processing?”
section of this notice.

Data portability


In case the legal basis of the processing is your consent or the
performance of a contract concluded by you, and data is processed in
an automated way, you have the right to receive your personal data
that you provided to us in a structured, commonly used and machine-
readable format, or to transmit those to another controller or
request us to directly transfer the data to another controller.

Complaint


In case you experience any problems in relation with our data
processing practices, you have the right to lodge a complaint with the
National Data Protection and Information Freedom Authority (1125
Budapest, Szilágyi Erzsébet fasor 22/C.; https://naih.hu/).
Furthermore, you are entitled to file an action at the competent
court.