PRIVACY POLICY

Confidentiality and security are of paramount importance to VIMBU, B.V. and we are therefore committed to ensuring your privacy at all times and to not collecting unnecessary information. Below, we provide you with all the necessary information about our Privacy Policy in relation to the personal data we collect, explaining:

1. PERSON IN CHARGE OF THE TREATMENT

VIMBU B.V.
81209517
Palmstraat 56 2V, 1015HS, Amsterdam
hello@vimbu.app
Hereinafter “Vimbu”, “us” or “Data Controller”.

2. PERSONAL DATA

This Privacy Policy covers all data collected and used by Vimbu through the platform, which comprises the Vimbu app and website ("Platform").
Therefore, this Privacy Policy applies to users of the Platform (hereinafter referred to collectively as the "Users" or "You").

3. PERSONAL DATA COLLECTED

Personal Data means any information or data that can identify you, either directly or indirectly.The provision of Personal Data requires a minimum age of 18 years or, where appropriate, have sufficient legal capacity to contract.Data that Users provide directly to us:Through the registration form as a User on the Platform: When you register, we collect the following identifying information:
- Name and surname
- E-mail address
- Password
• Through the form to purchase classes through the Platform:
When you purchase classes, we collect the following data:
- Your credit card details. In this regard, for your security, we have entrusted the system of payment by credit or debit card to a secure payment gateway. The bank details entered are encrypted and transmitted securely to the servers of the bank and then verified with the issuing bank to prevent fraud and abuse.
Through the User's profile: When you complete your profile, we collect the following data on an optional basis:
- Images of identifiable persons: Photographs of users.
- Any personal data that users may provide through this section.
Through the teacher form: When the teacher registers, we collect the following information.
Through the instant messaging service:
- Location of Users
- Any personal data that Users may provide through this section.
- We may collect/store information from Users when they use the Platform's internal messaging services for the purpose of maintaining communication between Users and instructors.

You guarantee that all information about your identity and legitimacy provided to Vimbu through the Platform is true, accurate and complete. You also undertake to keep your data up to date. In the event that you provide any false, inaccurate or incomplete information, or if Vimbu believes that there are reasonable grounds to doubt the veracity, accuracy and completeness of the same, Vimbu may deny you present or future access to and use of the Platform or any of its content and/or services. Similarly, the User must keep the password to make use of the services provided on the Platform, and agrees not to transfer its use to third parties.

Information you provide to us indirectly by creating an account and using the Platform:

Information on how you use our services, the functions you use and the actions you take. Consequently, in order to, among other things, connect users of the platform and teachers who teach classes.Information derived from your use of the Platform in aggregate form in order to implement improvements to the operation of the Platform and to provide you with recommendations that may be of interest to you.
You can learn more about this in our Cookie Policy here. Obligation to provide us with your personal data and consequences of not doing so. The personal data requested are necessary for registration on the Platform, the management of reservations and payments for the classes offered, as well as any service itself, so if you do not provide them, we can not serve you properly or provide the services you have requested through the Platform. In any case, we reserve the right to decide whether or not to include personal data and other information in our databases.

4. PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA

The personal data provided through the use of the Platform are necessary for the following purposes:
• Identify you as a user and be able to give you access to the different functionalities that are available to you as a registered user.
• Booking of classes.
• Purchase of classes.
• Execution of the payment of the purchased classes.
• To provide you with a way to contact us.
• Respond to your questions and/or requests.
• Enable direct contact with the Instructors through the Platform's messaging service or internal chat.

Other purposes related to the use of the Platform:
• The sending of promotions and advertising related to the services that may be of interest to you (sending of newsletters), subject to your express consent.
• Manage and follow up the contractual and pre-contractual relationship with the Users.
• Communicate with you, including by email, regarding new services, updates or any other matters relating to the operation of the Platform.
• Improve, develop and test our Platform.
• Protect the rights, property and/or safety of Vimbu.

On the other hand, for the proper functioning of the Platform, we may use technical and functional cookies to:
• The correct reception of technical recommendations, updates, security alerts and support messages.
• Improve the services you might subscribe to by studying your user behaviour to adapt it to your needs and tastes.
• The realization of reports and statistics, in a dissociated way.
• To research, develop and improve services to users or to offer new services, features and tools.

If you would like detailed information about the cookies we use, you can view our Cookie Policy here.

5. LEGITIMACY FOR THE PROCESSING OF PERSONAL DATA

• Manage your registration as a User: The processing of your data is necessary for the execution of the terms governing the use of the Platform. You are providing us with your consent by accepting this privacy policy through the established consent mechanisms.
• Similarly, we consider that we have a legitimate interest to carry out the necessary checks to detect and prevent possible fraud when you register on the Platform.
• To process the booking of classes: The processing of your data is necessary for the execution of the services that are published on the Platform. The basis of legitimacy in this regard, is your express consent at the time of registration.
• Manage purchases of classes offered on the Platform: The legitimizing basis is the contractual and pre-contractual relationship maintained with You at the time of acceptance of the Terms and Conditions of purchase of the services we offer.
• Sending commercial communications: The legitimate basis is the express consent you give us (for example: when you authorize the sending of advertising or our newsletter).
• User service: At Vimbu we have a legitimate interest in attending to the requests or queries of users through the various existing means of contact. We understand that the processing of this data is also beneficial to the user insofar as it allows us to adequately address and resolve the queries raised.For the management of incidents related to the use of the Platform, the processing is necessary for the execution of the contractual relationship with you.When the query is related to the exercise of the rights about which we inform you below, or claims related to our services, what legitimates us to process the data is the fulfillment of legal obligations on our part.
• Quality: We consider that we have a legitimate interest to analyze the usability of the Platform and the degree of user satisfaction, since the purpose is to improve the user experience and provide a higher quality service.

6. RECIPIENTS OF THE PERSONAL DATA COLLECTED

Your Personal Data may be communicated to third parties, that is:

• Instructors or sports schools with whom the User communicates and shares information, using our Platform. This data includes your name, profile picture.
• Third parties that help us provide IT services, such as Platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you.
• Third parties that help us provide digital services and reviews, CRM, web analytics and search engine.
• Advertising, marketing and digital media agencies to help us deliver advertising, marketing and campaigns, to analyse their effectiveness and to manage your contact and enquiries.
• Third parties for compliance with a legal regulation.
• Authorized Vimbu personnel.

We will ensure that any communication of your personal information by us or by third parties with whom we share your personal information complies with applicable laws.

7. PRESERVATION OF YOUR PERSONAL DATA

We will only keep your Personal Data for as long as we need it for the purpose for which we process it, until your account is deleted or for the legally required period of time.By deleting your account, we delete the published content, as well as the photographs. In any case, your data may be retained by law, for the period of time established, however, such data will be blocked.
The Personal Data obtained through registration on the Platform, through the reservation and purchase of classes and those obtained through a consultation or through instant messaging chat will be retained until the service is performed or during the time of attention for the resolution of your query. In the case of receiving your CV, your data may be kept for a maximum of one year for future selection processes.
The Personal Data obtained through your express consent to send commercial communications and / or newsletters, will be kept until you revoke your consent and request cancellation of the service.We may retain some personal information to comply with our legal or regulatory obligations and to administer our rights (for example, to enforce our claims in court) or for statistical or historical purposes.When we no longer need to use your personal information, it will be removed from our systems and records or anonymized so that we can no longer identify you.

8. RIGHTS IN RELATION TO YOUR PERSONAL DATA

Any person may withdraw their consent at any time, when it has been granted for the processing of their data. In no case, the withdrawal of this consent conditions the execution of the subscription contract or the relationships previously generated. You may also exercise the following rights:Request access to your personal data or its rectification when it is inaccurate.

• To request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
• Request a restriction of your treatment in certain circumstances.
• Request opposition to the processing of your data for reasons related to your particular situation.
• Request data portability in the cases provided for in the regulations.
• Other rights recognized in the applicable regulations.

Where and how to request your Rights: By writing to the responsible party at their postal or e mail address (indicated in section 1), indicating the reference "Personal Data", specifying the right you wish to exercise and with respect to which personal data.In case of disagreement with the company regarding the processing of your data, you can file a complaint with the Data Protection Agency (www.agpd.eu).

9. SECURITY OF YOUR PERSONAL DATA

In order to safeguard the security of your personal data, we inform you that we have adopted all the technical and organisational measures necessary to guarantee the security of the personal data supplied from alteration, loss and unauthorised processing or access.

10. UPDATING YOUR PERSONAL DATA

It is important that in order for us to keep your personal data up to date, you inform us whenever there has been any change in them, otherwise, we are not responsible for the veracity of the same.We are not responsible for the privacy policy regarding the personal data that you may provide to third parties through the links available on our Platform.

11. CONTACT

If you have any questions or concerns about how we process and use your personal data or wish to exercise any of the rights described above, please contact hello@vimbu.app. Publication date: 30 November 2021.