Privacy Policy

PRIVACY NOTICE

Last updated August 25, 2025

This privacy notice for Stark Ghent VZW (doing business as Stark Gent BJJ) ("Stark Gent BJJ," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at starkjiujitsu.be, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@starkjiujitsu.be.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by scrolling to each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Stark Gent BJJ and the Services, the choices you make, and the products and features you use. This includes information you provide directly (such as when a parent signs up their child), and technical information like your IP address, browser type, and usage data collected automatically. Scroll down for more info.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not generally receive personal information directly from third parties for our primary processing activities. However, our use of advertising platforms may involve us receiving aggregated or anonymized insights derived from data processed by these third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you (e.g., service communications), for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent, such as for remarketing via cookies. We process your information only when we have a valid legal reason to do so. Scroll down to learn more.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties, including service providers such as Zapier, Google Sheets, Meta (Facebook/Instagram Ads), and Google Ads for processing purposes outlined in this notice. Where data is transferred outside the EEA/UK, we rely on adequacy decisions or Standard Contractual Clauses approved by the European Commission. Scroll down to learn more.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Scroll down to learn more.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Scroll down to learn more.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what Stark Gent BJJ does with any information we collect? Scroll down to learn more.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. DO WE MAKE UPDATES TO THIS NOTICE?
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
12. COOKIE NOTICE

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• contact preferences

Children's Personal Information. We require that only parents or legal guardians sign up their children for gym membership and introduction classes. Our signup pages are designed to be completed by parents or legal guardians. We take reasonable steps to verify that consent is provided by the parent or guardian, for example by requiring that sign-up information is submitted using the parent's contact details. For minor members, we collect the following personal information directly from their parent or legal guardian:

• Minor's Name
• Minor's Birthday
• Parent/Legal Guardian's Name
• Parent/Legal Guardian's Phone number
• Parent/Legal Guardian's Email address

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: We may collect technical information such as your IP address, browser type, and usage data for security and analytics when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include technical information such as your IP address, browser and device characteristics, operating system, and information about how and when you use our Services. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies, as detailed in our Cookie Notice below.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you (e.g., service communications), for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent, such as for remarketing via cookies.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• Service Communications. To send you reminders and updates about your booked free introduction class or other training sessions. This may include communication via email, WhatsApp, or SMS.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• Remarketing and advertising. We may use information collected via cookies and similar technologies for remarketing campaigns on platforms such as Meta (Facebook/Instagram) and Google Ads. This helps us reach people who have already shown interest in our services.
• To enable member interactions. If you choose to join our optional WhatsApp community, your personal information (e.g., phone number, associated name/profile picture) may be processed and visible to other community members. Additionally, if you are a member, other members who sign up for classes may see your name as a participant on class attendance lists.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your explicit consent for certain activities, to fulfill our contractual obligations, for our legitimate business interests, to comply with legal obligations, or to protect your vital interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us explicit permission (i.e., consent) to use your personal information for a specific purpose, such as when you tick a box agreeing to reminders or remarketing. For data related to minors, this consent must be provided by the parent or legal guardian. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you. For example, when you book a free class, we may send you service-related reminders as this is necessary to deliver the service you requested.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. This may include processing for internal administrative purposes, network and information security, detecting and preventing fraud, and for internal analytics and reporting.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations and with specific third parties, including service providers who may process data outside the EEA/UK.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Service Providers / Processors. We use trusted third-party providers such as Zapier (automation platform), Google Sheets (data storage), Meta (Facebook/Instagram Ads), and Google Ads (advertising platforms) to process your data strictly for the purposes described in this privacy notice. These service providers act on our behalf and are contractually bound to protect your information.
• International Data Transfers. Some of our service providers are based in countries outside the European Economic Area (EEA) and the UK, notably the United States. Where data is transferred outside the EEA/UK, we rely on adequacy decisions (where the European Commission has deemed a country to provide an adequate level of data protection) or Standard Contractual Clauses (SCCs) approved by the European Commission. We ensure these providers implement robust technical and organizational measures to protect your data, and where necessary, we implement supplementary measures.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice below.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

• Introduction Class Sign-up Data: Information collected from individuals who sign up for an introduction class via our Google Sheet is generally kept for a period of up to 36 months after their last interaction or class date, unless they become a member, in which case their data is transferred to the member database and retained as per membership terms.
• Member Data: Personal information for active members is retained for the duration of their membership. Following the termination of membership, we may retain certain data for a period of up to seven years to comply with legal obligations (e.g., tax, accounting, or potential legal claims).
• Marketing Consent Records: Records of your consent for marketing communications are retained for a reasonable period after you withdraw consent, to demonstrate our compliance with applicable laws.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. For data related to minors, this right can be exercised by the parent or legal guardian. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.