Privacy Policy
Privacy Policy – MyTrainingMap
MTM Sport Ltd (hereinafter “MTM” or “we”, “our”, “us“ and similar expressions) owns and operates the MyTrainingMap platform, an online marketplace for the exchange of information and conclusion of agreements on the provision of camp-related services between owners, providers and/or advertisers of sports training facilities and related services (Camp Service Providers) and persons searching for such facilities and services (Camp Planners) (hereinafter also the “Marketplace” or “Service"). For the purposes of this Privacy Policy, users of the Marketplace, i.e., Camp Service Providers, Camp Planners, and in instances where the afore mentioned are legal and not natural persons (i.e.., companies or some other kinds of entities), meaning instead the natural persons using the Marketplace on behalf of those Camp Service Providers and/or Camp Planners, as well as other website visitors are hereinafter referred to as “user(s)” or “you”, “your”, “yourself” and by similar expressions.
This Privacy Policy describes how we collect, use, share, store and otherwise process your personal data when you visit this website or use and/or sign up for the Service. In this Policy, “Personal Data” has the same meaning as under the EU General Data Protection Regulation (“GDPR”), meaning any information about an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, whether directly or indirectly, by reference to an identifier such as a name, email address or an online identifier or to one or more other factors specific to that natural person.
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 Data We Process
Situations where you may make Personal Data available to us include without limitation:
i. visiting this website;
ii. using and/or registering for the Service; or
iii. sending us email messages or through other means of communications directed at us.
The Personal Data we collect and process may include:
- information collected via the use of cookies and similar technologies (like web beacons/pixel tags), including your visitor information such as your IP address, browser details, device information and the pages you visit on our website;
- your name, email address and other contact details as well as other personal details which we may ask for and which you may provide us on the Marketplace for purposes of identification, communication and other use of the Marketplace;
- details on your communications with us, including without limitation any messages, notifications, requests and similar sent to us by email, by using the Marketplace features or otherwise;
- your account details and Marketplace activity information, including without limitation your account settings as well as the information and content you provide us in connection with any
- Listing(s) you post on the Marketplace, or any other information related to your account; and/or
- 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 Policy, we rely on the following legal bases for processing your Personal Data:
- Contract: i.e., where necessary for:
- the fulfilment of your requests prior to entering into a contract, for example, requests for information; and/or
- the performance of a contract between you and us, in particular, providing you the platform service described in the Terms.
-
Legal obligations: i.e., where necessary for our compliance a legal obligation, such as mandatory provisions of accounting and tax laws.
-
Legitimate interests: i.e., where necessary for our legitimate interests (in particular, to operate the Marketplace and to otherwise conduct and develop our business), except where such interests are overridden by your privacy interests or fundamental rights and freedoms. This is the legal basis we mainly rely on for activities not covered by the above-mentioned legal bases, such as for managing our relationships with the parties on the Marketplace as well as developing and marketing our services.
In individual cases, and where legally required, we may also obtain a separate consent from you, e.g., when we seek to set cookies on your device or use similar technologies for purposes of web analytics or customizing the content we present to you. 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 Process Your Information
We may use and process your Personal Data for the following purposes, and where permitted by the Article 6(4) of the GDPR in particular, purposes compatible with the following:
- Providing our services to you and ensuring the smooth functioning of the Marketplace, including helping Buyers easily find and agree on, and Sellers provide and charge for, the appropriate services
- Managing your account and your Marketplace activities
- Invoicing you for Marketplace-related services, and for debt recovery purposes
- Responding to any issues or inquiries you may have regarding the Marketplace and our services and providing you with information relevant to your use of the Marketplace , such as updates on scheduled downtime, new features or issues related to your use of the Marketplace
- Contacting you with offers, promotions and other direct marketing – you may always, however, opt out of such communications
- Safeguarding and maintaining the Marketplace, and preventing, identifying and repairing any technical problems and security issues
- Preventing, detecting, mitigating and investigating fraud, criminal activity or other misuse of the Marketplace
- Performing research and statistical analysis on the Marketplace, including analyzing the use of our Service
- Better allocating our resources and enhance and improve the services provided to you and to other users of the Marketplace
How We Share Your Information
We may disclose your information to the following recipients, but only where necessary for the above purposes of processing:
- Companies involved in performing services for or on behalf of us in connection with our Service. In particular, Sharetribe is our technology and hosting provider for the platform backend and several other Marketplace features. Information about sub-processors employed by Sharetribe can be found here.
- Partners and agents who assist in or carry out the processing of the transactions you make. For processing payments, we use Stripe.
- Service providers who help us in reaching our customers by direct marketing and retargeting, such as HubSpot, Google and Meta.
- Debt recovery service providers engaging in debt recovery on our behalf in connection to your use of the Marketplace.
- Law enforcement agencies, courts, regulatory organizations or other public authorities, provided we are required and authorized to do so by law.
- Any other person – but only with your separate consent unless otherwise provided by applicable law.
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 our partners, 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 for this where required.
How We Secure and Store Your Information
Your Personal Data is stored in accordance with this Privacy Policy and any applicable laws in secure locations and servers as follows:
- Our premises are physically protected with mechanical and electrical locks and other break-in prevention methods
- 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
- 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 (see here for the list of countries subject to such adequacy decision), including transferring to recipients who have certified to participate in the EU-U.S. Data Privacy Framework, or where we have taken appropriate safeguards to require that your personal data remains protected in accordance with this Policy, 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 with a Marketplace participant 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 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 our Service. This information can be, for example, aggregated data on the demographics or usage patterns of Marketplace 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