Privacy Policy — SIM App

1. Introduction

This Privacy Policy explains how ÁBB Kft (“we”, “us”, “our”) collects, uses, and protects personal information when you use the SIM mobile application (“App”). We are committed to protecting your privacy and ensuring the security of your personal data in accordance with the General Data Protection Regulation (GDPR – EU 2016/679) and applicable Swedish data protection laws.

2. Data Controller

ÁBB Kft
Registered address: 2310 Szigetszentmiklós, Hungary
Email: arpad.sooky@simtraining.eu

3. Data We Collect

The SIM app collects and processes only the data necessary for participation in the SIM training program:

• Name
• Email address
• Health-related data voluntarily provided by students during participation in the health survey

Note: No location data, payment information, device identifiers, or analytics data are collected. No third-party tracking or advertising services are used.

4. Purpose and Legal Basis of Processing

Personal data is processed for the following purposes:

• To register and manage teachers and students within the SIM program
• To provide access to training materials
• To enable participation in health-related surveys connected to the SIM study

The legal basis for processing is:

• Article 6(1)(b) GDPR – performance of a contract (to provide the training service)
• Article 9(2)(a) GDPR – explicit consent of the data subject for processing health data

Participation in the health survey is voluntary. If consent is not given, students may still access general training materials, but will not participate in the health study.

5. Data Retention

We retain personal data for the duration of the study plus six (6) months after completion. After this period, personal data is securely deleted or anonymized.

6. Data Storage and Security

All data is stored exclusively on servers located within the European Union, using EU-based service providers. We apply strict security measures, including encryption in transit and at rest, access control, and regular audits, to protect your data against unauthorized access, alteration, or disclosure.

7. Data Sharing and Processors

We do not share personal data with third parties for marketing or analytics. Processing is carried out by ÁBB Kft, which has a legal data processor agreement with the SIM program. No other external processors or third-party integrations are used.

8. Rights of Data Subjects

Under the GDPR, you have the following rights:

• Right of access – to obtain confirmation and a copy of your data
• Right to rectification – to correct inaccurate data
• Right to erasure – to request deletion (“right to be forgotten”)
• Right to restriction of processing – to limit use of your data
• Right to data portability – to receive your data in a structured format
• Right to withdraw consent – at any time, without affecting lawfulness of prior processing

Requests can be made via email to support@simtraining.eu.

9. Children’s Privacy

The SIM app may be used by students under the age of 18, under the supervision or consent of a parent, guardian, or educational institution. We do not knowingly collect personal information directly from children without appropriate consent.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any significant changes will be communicated within the app or via email before they take effect. The “Last updated” date at the top will reflect the latest version.

11. Contact