Privacy Policy – MyTrainingMap Platform

MTM Sport Ab (hereinafter ”MTM” or “us“, “our“ and similar expressions) offers an online platform service for information exchange between owners, providers and/or advertisers of sports training facilities and related services and persons searching for such facilities and services (“Platform”). When a user of our service (hereinafter “you”, “your”, “yourself” and similar expressions) uses and/or registers for our service, we collect, use, share and store information on the user (“your information”) in the manner described in this policy. Below, we wish to inform you on how your information, and in particular any personally-identifiable information we may hold about you, is collected, used, stored, disclosed and removed (each and all referred to as “processing”).

Any capitalized expressions, if not defined herein, shall have the same meaning as defined under the Terms of Use for the MyTrainingMap Platform (“Terms”).

The Information We Process

For purposes of this Privacy Policy, “Personal Data” means personally identifiable information that specifically identifies you as an individual.

Situations where you make, or may make, Personal Data available to us include without limitation:

  1. using and registering for the Platform; or
  2. sending us email messages or through other means of communications directed at us; or

The Personal Data we collect and process may include without limitation:

  1. Your name, email address and other contact details as well as other personal details we may ask and you may provide us in the context of the Platform for purposes of identification, directing communications and use of the Platform;
  2. Details on your communications with us, including without limitation any messages, notifications, requests and similar sent to us by email, by using the Platform features or otherwise;
  3. Your account details and Platform activity information, including without limitation your account settings as well as the information and content you provide us in connection with any Advertisement(s) you post on the Platform, or any other information related to your account; and/or
  4. Credit or debit card information and/or other banking information to be processed by our payment service provider partner(s);

Legal Bases of Processing

For the activities described in this notice, we rely on the following legal bases for processing Personal Data:

  1. Fulfilment of your requests prior to entering into a contract, for example, requests for information;
  2. Performance of a contract between you and us, in particular providing you the Platform service described in the Terms;
  3. Compliance with our legal obligations, such as data retention obligations related to accounting and taxation;
  4. Our legitimate interests to conduct and develop our business, where your interests and fundamental rights do not override those interests: This is the legal basis we mainly rely on for activities not covered by the above-mentioned legal bases, such as for managing our customer relationships as well as developing and marketing our services.

In individual cases, and where legally required, we may also rely on your separate consent. You may later revoke your consent at any time.

If you need details about the grounds we are relying on with respect to specific data or circumstances, please contact us as set out below.

How We Use Your Information

We may use and process your information to:

  1. Provide our services to you and to enable Hosts on the Platform to provide you with the services they advertise
  2. Manage your account and your Platform activities
  3. Invoice you for Platform-related services, and for debt recovery purposes
  4. Respond to any issues or inquiries you may have regarding the Platform or our services and provide you with information relevant to your use of the Platform, such as updates on scheduled downtime, new features or issues related to your use of the Platform
  5. Contact you with offers, promotions and other direct marketing – you may always, however, opt out of such communications
  6. Protect and maintain our network and the Platform, and to prevent, identify and repair any technical problems or security issues
  7. Prevent, detect and investigate fraud, criminal activity or other misuse of the Platform
  8. Perform research and statistical analysis on the Platform, including observing how our customers use the Platform
  9. Better allocate our resources and enhance and improve the services provided to you and to other users of the Platform

How We Share Your Information

We may disclose your information to:

  1. Partners or agents who assist in or carry out the processing of the transactions you make. For processing payments, we use Stripe.
  2. Companies who are involved in performing services for or on behalf of us in connection with our Platform service. For hosting our website, we use Azure.
  3. Service providers who help us in reaching our customers by direct marketing and retargeting, such as HubSpot, Google and Facebook.
  4. Debt recovery organizations engaging in debt recovery on our behalf in connection to your use of the Platform
  5. Law enforcement agencies, courts, regulatory organizations or other public authorities if required or authorized to by law

Your Personal Data may be disclosed only for the purposes specified above in this Privacy Policy.

We may also transfer your information to other third parties, if we need to counter or prevent any malicious or fraudulent actions, or to invoke any available legal remedies or to limit potential damage incurred to us, or if we sell, merge, de-merge or otherwise restructure our business operations and a new party becomes the owner of the information.

We may also share your information with carefully selected partner organizations, so they can let you know about their products and services – provided, however, that we have obtained your consent where necessary.

How We Secure and Store Your Information

Any collected Personal Data is stored in accordance with this Privacy Policy and any applicable laws in secure locations and servers as follows:

  1. Our premises are physically protected with mechanical and electrical locks and other break-in prevention methods
  2. Our data connections utilize firewalls and protection from malicious programs, as well as other protection mechanisms and software which improve the security of our telecommunications and data connections
  3. Only designated persons and a limited amount of our personnel have access to the information. Our personnel have been trained to observe data security in their work.

As a general rule, your personal data will not be transferred to countries outside the European Union or the European Economic Area, except where the European Commission has held that the country ensures an adequate level of protection for personal data, or where we have taken appropriate safeguards to require that your personal data remains protected in accordance with this notice, such as by implementing the European Commission’s Standard Contractual Clauses for transfers of personal data. You may contact us for more information on the safeguards in place. In individual cases, however, such transfers may also take place based on your separate consent or in order to provide you with a service you have specifically requested, or where otherwise allowed by applicable data protection laws.

Data Retention

We keep your Personal Data only as long as we have a legitimate business need to retain it for the purposes described above, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider the scope, nature, and sensitivity of the Personal Data we process, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data and the relevant legal requirements. We will also regularly assess the data we keep, and where we deem retention unnecessary, we will either erase or anonymize the data or, if this is not possible – for example, for information stored in backup archives – we will store the data securely and block any further processing until deletion is possible.

We will usually retain Personal Data related to an individual customer relationship only for the duration of the relationship and for a reasonable period thereafter in order for us to be able to, for example, respond to inquiries or resolve pending issues related to the relationship. This period is usually three (3) years from the end of the customer relationship. However, some data may be retained for longer where we believe retention is necessary for compliance with laws or regulations (such as in the fields of accounting and taxation), or to exercise, establish or defend our legal rights or those of our customers, affiliates or partners.

Please note that some of your Personal Data may be anonymized and we may continue to use, process and store it after you cease to use the Platform. This information can be, for example, general-level data on the demographics or usage patterns of Platform users.

Your Rights as a Data Subject

You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed by us, and where that is the case, access to that Personal Data as well as to have any inaccurate or incomplete Personal Data rectified or completed. In certain circumstances, you may also have the right to request the erasure, or the restriction of processing, of your Personal Data or parts of it, to object to the processing and/or to receive the data in a structured, commonly used and machine-readable format.

Please contact us for any inquiries related to exercising the above rights.

If you consider our processing activities of your Personal Data to be inconsistent with applicable data protection laws, you may lodge a complaint with the responsible supervisory authority. Contact information for the supervisory authority in Finland can be found here: www.tietosuoja.fi

Changes to This Policy

We may update this notice from time to time in response to changing legal, technical or business developments. When we update this notice, we will strive to inform you in a manner consistent with the significance of the changes we make.

Data Controller

MTM Sport Ltd (Business-ID: 3006641-4)

Bumlingestigen 47
65410 Sundom
Finland

E-mail: info@mytrainingmap.com