Privacy Policy | Easy Padel

PRIVACY POLICY

We, at CODEDUNES SOLUTIONS – FZCO ("we," "our," and "us"), prioritize privacy and aim to ensure that you feel secure when we handle your personal data. We are dedicated to safeguarding your integrity through our diligent efforts.

This privacy policy is applicable to individuals utilizing our online booking system and service, referred to as the "Platform", which can be accessed on our website www.easypadel.com or through our Platform app, known as the “App”.

In the following sections, we elucidate the reasons behind processing your personal data, outline your rights in this regard, specify the legal basis governing our data handling practices, and detail the duration for which we retain your information.

Who oversees the processing of your personal data?

CODEDUNES SOLUTIONS – FZCO (license number 28506), is responsible for the processing of your personal data.

Kindly be aware that we also handle data on behalf of our partners and venues. If you have any inquiries concerning this matter or if you wish to exercise your rights under data protection legislation, please reach out to us via our email address [email protected] or send a traditional letter to our postal address Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates.

Where do we obtain your personal data from?

We gather your personal data directly from you during the registration of your Platform account or when you engage with the Platform. This includes instances such as making a booking on our website, through our App, or on a venue's website if the bookings are facilitated by the Platform. Additionally, when you opt to update or supplement your account information, we may collect relevant data. While much of this information is voluntary, providing more details enhances the functionality you experience when using the Platform.

We may also obtain your personal data from alternative sources in the following scenarios:

When you book an activity, participate in a competition, or become a member of a partner or venue, the partner or venue may furnish us with your information, which we then process on their behalf.
If you utilize the Platform with your personal Facebook or Apple account, we will leverage data from these accounts to manage your Platform account.
If you opt to activate the optional matchmaking function, we will gather personal data, specifically statistics, from our affiliated partners and venues to offer you matchmaking opportunities.

The personal data required from you

In general, furnishing personal data to us is not obligatory. However, specific information must be provided to use the Platform or any of the Apps. The situations necessitating the provision of personal data are outlined in the charts below, where the legal basis is indicated as “Performance of a contract” or “Legal obligation”. Failure to provide such personal data may, for instance, result in the unavailability of the Platform or the App for you.

Who has access to your personal data and for what reasons?

Your personal data is primarily processed by the Platform. This implies that our employees and representatives handle your personal data only to the extent necessary for them to fulfill their work duties.

Certain details about you may be visible to others, and whether information is public or not is clearly indicated within the system. You have control over this visibility through your account's privacy settings or the choices you make when using the Platform or the App, allowing you to select the level of visibility you prefer. The more information you share, the greater access you will have. Please be aware that when using the App, there are fewer options to set your profile to private, and most information is visible to others participating in a competition, potentially displayed on screens at a venue or other suitable locations. It's generally required to use your real name in the App, as competitions often take place in real life, and your team members or competitors have a legitimate interest in knowing who they will be interacting with.

At times, our partners or venues act as administrators on the Platform. In this capacity, they may process your personal data if you are associated with them through your membership or as their customer. Additionally, they might display information about activities or events on screens at the venue, and such displays can incorporate information entered into the Platform.

In specific instances, it is necessary for us to share your personal data with our suppliers, partners, and subsidiaries to facilitate the efficient operation of our business. We bear the responsibility for any sharing of your personal data with such suppliers, partners, or subsidiaries and ensure the security of your personal data when shared with third parties.

We may disclose your personal data to the following recipients:

Our IT suppliers, who will process your personal data on our behalf as processors, ensuring the functionality of our IT system and the efficient operation of our business. The sharing of your personal data is limited to the extent necessary for our suppliers to fulfill their contractual obligations with us, strictly in accordance with our instructions. This applies to all detailed schedules listed below.
If you receive our newsletters or participate in surveys, we will share your personal data with the company that provides the system for sending newsletters or conducting surveys.
Our affiliated partners and venues, allowing you to, for example, enter a competition or utilize the booking you made through the Platform with the partner or venue. The sharing of your personal data is limited to what is necessary for our affiliated partners and venues to fulfill their contractual obligations either with us or directly with you. The venues will process your personal data as controllers since you are also a customer of the venue. There may be some overlap in the information we process and control about you and the information the venue processes and controls. More details on this can be found here.
Our payment service providers for the purpose of managing your payments.
To retain information mandated by bookkeeping, accounting, and other compulsory laws, we may, in certain instances, engage a company to assist us in archiving such data. The information includes personal data but will only be processed on our behalf and in accordance with our instructions.
Analytic services are primarily offered by Google Ireland Limited, and the checkbox service to confirm that you are not a robot is also provided by Google Ireland Limited. Consequently, Google processes your personal data on our behalf and in accordance with our instructions as our processor. Subsequently, Google processes your personal data as a controller. For more details about Google's processing, refer to this link.

Where is your personal data processed?

We and our processors handle your personal data within the EMEA. In certain situations, we may transfer your personal data outside of the EMEA to our IT suppliers who process personal data as our data processors and in accordance with our instructions. Such transfers only occur in compliance with relevant data protection legislation, ensuring that your personal data is transferred outside the EMEA only when an appropriate level of protection is guaranteed.

Comprehensive explanation of how we handle your personal data

The following charts provide a detailed description of why we process your personal data, the categories of personal data we process, the legal basis for processing according to the General Data Protection Regulation (GDPR), and the duration for which we process your personal data. The legal basis serves as the foundation for our processing of your personal data in accordance with the GDPR.

This information, in part, is required due to legal obligations and may seem extensive and intricate. If you have any questions about how we process your personal data, please feel free to reach out to us. Our contact details are available at the beginning of this privacy policy.

Processing which we are solely responsible for

If you use the Platform

To administrate your Platform account

Purpose of processing	Personal data we process	Legal basis for processing
Platform account registration Conclusion of an agreement with you for your Platform usage Facilitating your account login on our website, app, or on a website/application with Platform-powered bookings Sending an email to provide instructions for password change upon request Communication with you as required to fulfill our contractual obligations, including sending updates about the Platform or the App.	Name E-mail address Password	Performance of a contract The processing is essential for us to initiate and fulfill the contract we have with you regarding your use of the Platform. If the data is not provided to us, we will be unable to manage your registration and account.
Facilitate the verification that you are not a robot during the account registration process Share your IP-address with Google	Confirmation from Google that you are not a robot IP address	Legitimate interest The processing of personal data will be conducted based on our legitimate interest in verifying that you are not a robot.
Duration of storage: until you opt to delete your Platform account. The personal data processed to verify that you are not a robot during the account registration will only be processed until your account is registered.

Providing features for your platform account

Purpose of processing	Personal data we process	Legal basis for processing
Facilitating the creation of a personal profile Displaying your previous and upcoming bookings Sending you booking information, including entry codes, and facilitating the sharing of booking details with invited players Generating and displaying statistics, such as those based on your previous bookings If you apply for or purchase membership, we may request your social security number, as venues in some countries often require it to apply for grants or funding.	Name E-mail address Booking information (e.g., the partner or venue booked, specific court, day and time of booking, and, if the invitation feature is used, the list of invited players) Additionally, we process information that you choose to register, such as: Birthday Gender Location Nationality Phone number Address Profile picture Personal description and sports profile Any information you may choose to add	Performance of a contract The processing is necessary in order for us to fulfil the contract we have with you to provide the features of your Platform account. Legitimate interest The processing of the personal data that you choose to register on your profile will be carried out based on our legitimate interest to enable a personalized profile on the Platform.
If you download the App, for facilitating the administration and organization of competitions. Enabling you to accept or activate invitations from competition organizers. Displaying your previous and upcoming competitions / matches with other participants and results. Sending you competition-related information and facilitating communication with other participants in the same competition as yourself.	Information on matches. Results Contact information, such as phone number and email Information you add, such as in communication with other fellow participants, entered scores, or uploaded pictures/images.	Performance of a contract The processing is necessary for us to fulfill the contract we have with you, specifically to provide the features of your Platform account and, in particular, the App. Legitimate interest The personal data entered for competitions connected to your profile will be processed based on our legitimate interest to enable your participation in competitions using the App.
The App may require access to your device camera to enable scanning QR codes, which are used for tournament purposes. The App will not store or access any pictures on your device but will only use the camera to scan QR codes. It is your choice whether to allow access or not.	QR-codes	Consent We will process your data for this purpose only if you have given your consent.
Suggesting relevant activities for you based on your use of the Platform and information about your activities at our connected partners and venues. This is primarily based on whether you have chosen a favorite club or location in the Platform.	Gender Age Location Previous booking information Information from your sports profile	Consent We will process your data for this purpose only if you have given your consent.
Enabling you to find a partner and venue near you if you choose to. Please note that you can deactivate this feature on your device if you do not wish to make use of it.	Geolocation	Legitimate interest The processing of the personal data that you choose to register on your profile will be carried out based on our legitimate interest to assist you in finding partners and venues near you.
Fostering a more social environment on the Platform. Allowing you to search for other users. Allowing you to see which other users have signed up for a specific activity or event at a venue. Inviting other players to connect with you in general or to a specific booking that has been made.	Name Thumbnail image Information about a specific activity or event, including the players who have enrolled or been invited to participate. Relevant user information entered in fields marked with public visibility.	Legitimate interest The processing of the personal data that you choose to register on your profile will be carried out based on our legitimate interest to create a more social Platform.
Enable our matchmaking function which uses the data you provide yourself and collects information about you and your booking history to match you with another player at a similar level. The above is done to show you relevant activities and matchmakings that are relevant to you. We do this because without it, you would instead see offers and information which you are probably not interested in and you would not be able to find another player at a similar level as you.	Gender Age Location Previous booking information Information from your sports profile	Consent The inclusion of the matchmaking function is at your discretion, and we will only handle your personal data for this purpose if you choose to enable this function, indicating your consent to our processing of personal data. We will solely process the information you decide to input. You have the freedom to revoke your consent at any given time. The most effective method for doing so is to deactivate the associated function and eliminate any information you no longer want to undergo processing. Furthermore, you possess the right to object to the outlined processing, and further details about this can be found in the section elucidating your rights.
Duration of storage: We will handle your personal data for this specific purpose until such time as you opt to unregister or delete your account.

To gather information from our affiliated partners and venues

Purpose of processing

Personal data we process

Legal basis for processing

Gather information about you from our affiliated partners and venues, and compile relevant statistics.

Previous booking, activity or competition information
Name
Information about your membership

Legitimate interest

The processing of personal data will be carried out on the basis of our legitimate interest, aiming to compile statistics.

Duration of storage: We will handle your personal data pertaining to statistics until you decide to delete your Platform account.

To offer customer service and support

Purpose of processing

Personal data we process

Legal basis for processing

rovide customer service and address any questions you may have regarding your use of the Platform and/or the App.

Name
Phone number
E-mail address
Information about the support matter

Legitimate interest

The processing of personal data will be carried out based on our legitimate interest in providing customer service.

Performance of a contract

The processing may also be deemed necessary to fulfill the contract we have with you regarding your use of the Platform. If the required data is not provided, we may not be able to assist you.

Duration of storage: We will handle your personal data pertaining to statistics until you decide to delete your Platform account.

To analyze the usage patterns of the Platform.

Purpose of processing

Personal data we process

Legal basis for processing

Analyze your usage of the Platform and/or our App to enhance our website and services. This involves utilizing the analytic service provided by Google Analytics.
The analytic service involves assigning a random ID to your device to differentiate it from other visitors and recognize patterns in how our website is used. However, we will not have knowledge of your identity.
The collected personal data will be utilized, for example, to optimize functions and tailor the websites to better suit the preferences of our visitors.
We will collect personal data through the use of cookies, and you can find more information about our cookie usage here.

An encrypted version of your IP address
Information about your device/browser, and if you use multiple devices, details such as the geographical area within the country from which you access our website and your screen resolution.
• Information about your activities on the website, such as what you click on and the frequency of your visits to the Website.
Other information that Google has about you, including details such as the site from which you found us.
The aforementioned provides a summary of the most pertinent information, but it is a highly technical process, and there may be additional details related to the above that will undergo processing.

Legitimate interest

The processing of personal data will be conducted under our legitimate interest to deliver and enhance our customer service.

To prevent Google Analytics from using your personal data, you can download and install this browser add-on.

Occasionally, various cookies may be employed. If these cookies are non-essential to the service, we process the data with your consent. In such instances, you have the option to withdraw your consent at any time.

Duration of storage: We will retain your personal data until the point of account deletion at the latest, though certain data may be deleted earlier. Google will continue to store your personal data for their own purposes, and you will receive separate notification from Google regarding such storage.

To send newsletters, surveys and keep you informed

Purpose of processing

Personal data we process

Legal basis for processing

Send information about news, marketing, offers and invitations (“newsletters”)
Send surveys with enquiries related to aspects of our service, the wider market which we cater to or potential future developments.

E-mail address
Telephone number
Information as to whether you wish to receive such communications.
The results from surveys are anonymous so we do not process any answers from you as personal data.

Legitimate interest

The processing of personal data will be carried out based on our legitimate interest to send marketing material, provide broader information, and gather survey results to enhance our service and decision-making processes.

Duration of storage: We will process your personal data for this purpose as long as you maintain the Platform account. You have the option to unsubscribe or object to receiving newsletters, surveys, and marketing at any time. If you choose to object to receiving marketing from us, we will maintain a record of this in our "unsubscribe-list" to ensure that you do not receive further such materials. Additionally, you can actively specify your preferences in your account settings at any time, indicating whether you wish to receive newsletters and/or participate in surveys.

To address cancellations, complaints, or claims.

Purpose of processing

Personal data we process

Legal basis for processing

Address any cancellations, complaints or claims
Initiate potential claims or defend ourselves against a possible complaint or claim.

Name
Contact details you have chosen to use, e.g., e-mail address and/or phone number
Information from our communication with you in relation to the claim

Legal obligation

The processing is deemed necessary to adhere to legal obligations, specifically consumer law. In such cases, providing your personal data is imperative, as failing to do so would prevent us from fulfilling your consumer rights.

Performance of a contract

The processing may also be necessary for us to fulfill the contract we have with you regarding your use of the Platform. If the required data is not provided, we may not be able to assess and meet contractual obligations.

Legitimate interest

We also have a legitimate interest in processing your personal data to defend ourselves against a potential complaint or claim.

Duration of storage: We will retain your personal data from the initiation of the complaint or claim and throughout the duration of such complaint or claim. If you have a Platform account, we will store the information for as long as your account is active.

If you object to receiving marketing from us

We will retain information about individuals who have chosen to object to receiving marketing from us. Refer to the chart below for details about this data, which we have received directly from you.

To comply with marketing legislation

Purpose of processing

Personal data we process

Legal basis for processing

If you have expressed a desire not to receive marketing from us, we will store such information in an "unsubscribe-list" to ensure that we refrain from sending any marketing material to you.

E-mail address
Telephone number
Your objection to receive marketing

Legal obligation

The processing is deemed necessary to comply with legal obligations, specifically marketing laws that mandate refraining from sending marketing material to individuals who have objected to receiving such communications.

Ensuring that you do not receive marketing from us requires processing your personal data for this specific purpose. Therefore, providing your personal data is a requirement in order for us to fulfill this legal obligation.

Duration of storage: You will be included in our "unsubscribe-list" until further notice.

To comply with bookkeeping, accounting and transaction related obligations

Purpose of processing

Personal data we process

Legal basis for processing

Store information in bookkeeping and accounting records.
Document information to fulfill legal requirements, such as knowing our customers as required by law.

Name
History of payments made and other information that constitutes accounting records.
“Know your customer” information, if mandated by legal requirements.

Legal obligation

The processing is essential to comply with legal obligations imposed on us, such as bookkeeping and accounting legislation, or other legislation related to transactions to counter money laundering, terrorism, or adhere to sanctions.

Duration of storage: We will retain any document constituting bookkeeping material and the personal data included therein for a period of seven to eight years, in accordance with bookkeeping and accounting legislation. This regulation stipulates that we store bookkeeping material until and including the seventh year after the end of the calendar year for the fiscal year to which the personal data relates.

Processing for which we, our partners, and venues each have individual responsibility

For certain processing of your personal data, we function as a processor to our partners and venues. In such cases, they include some of your personal data in the Platform. This data may overlap with the information we control, and at times, it might contain additional details, such as membership status. If you, as a Platform user, make a purchase, booking at a venue, or participate in an activity or competition, we will transmit your information to the venue. As their customer or member, the venue is responsible for independently processing your data, separate from our control.

Should you have any requests regarding the data we process on behalf of our partners or venues, we will always need to consult the controller (our partner or venue) before taking any action. For information about how a specific venue or partner processes your data, we advise you to contact the venue directly. You can find contact details for the responsible partner or venue in the Platform, as well as in your booking information or receipt. If you are a member or customer of a particular venue, other venues not affiliated with yours will not be able to access your personal data processed by us on behalf of a specific venue.

The overlapping data is outlined in the schedule below, detailing our purposes and legal basis for processing. This information is provided to offer an overview of the involved data and is not exhaustive. Each venue processes information for its own purposes, which may differ from ours, and they make their own decisions regarding the grounds for processing.

To administer your bookings, purchases, activities, applications, and memberships

Purpose of processing	Personal data we process	Legal basis for processing
Receive and register your bookings, purchases, and applications. Administer your purchases and payments. Share your payment information with payment service providers.	Name Contact information Booking details (e.g., the partner or venue you booked, the specific court, day, and time of the booking) Information about your purchase or application Competition information Payment information	Performance of a contract The processing is essential for us to fulfill the contract we have with you regarding your use of the Platform. Without providing the necessary data, we will be unable to administer your bookings and purchases at venues.
Share information with and receive information from our affiliated partners and venues.	Name and contact information, such as email address or phone number Booking information, including details about the court, day, time, and participants involved Membership purchases, specifying contact information, social security number, birthday, gender, and any additional information you choose to provide and that is required by venues Information regarding your status as a student or pensionary	Legitimate interest The processing of personal data will be carried out based on our legitimate interest to fulfill our contractual obligations with our affiliated partners and venues. This is essential for them to fulfill their obligations in the contracts they have with us and with you. We act solely as a mediator when providing booking services, selling vouchers, or memberships.
Duration of storage: We will retain your personal data for as long as necessary to administer your booking and purchase. Subsequently, we will continue to process your personal data for the purposes outlined in the charts above, such as managing your account, providing its features, or for bookkeeping purposes, among others. Moreover, our affiliated partners and venues bear responsibility for your bookings, activities, applications, and purchases. They will store your information in line with their own privacy regulations. To the extent that the venue's information is stored by the Platform, we process this personal data on behalf of the venue and in accordance with our data processing agreement with the venue.
Sharing: When you accept an invitation to a booking, make a booking, application, purchase, or participate in activities or competitions at a venue, we will transmit your information to the venue. As their customer and/or member, they are responsible for independently processing your data, separate from our control.

Your rights when we process your personal data

Right to information and access

You possess the right to confirm whether we are processing your personal data. This includes comprehensive details such as:

The purpose of the processing.
Categories of processed personal data.
Recipients or categories of recipients with whom personal data may be shared, especially if located in third countries.
Expected retention times for storage or the criteria used to determine such durations.
Information about your rights to have personal data corrected, deleted, or its processing limited, as well as your right to object to such processing.
Your right to file a complaint with a supervisory authority.
Any application of automated decision-making, including profiling in accordance with GDPR Articles 22.1 and 22.4.
If personal data is transferred to a third country or international organization, your right to information about the measures, in line with GDPR Article 46, taken to ensure an appropriate level of data protection.

Moreover, you have the right to obtain a copy of the personal data we process. Additional copies may incur a reasonable fee for administrative costs if requested, and if provided through email, the information will be delivered in a common electronic format.

Right to rectification

You have the right to rectify any inaccuracies in your personal data that we are processing and to request the completion of any incomplete personal data.

Specifically, in alignment with the purpose, you are entitled to supplement any incomplete personal data. Whenever feasible and with reasonable efforts, we will notify each recipient with whom the personal data has been shared of any corrections made. If you wish to obtain further details about these recipients, please feel free to reach out to us. Our contact information is available at the beginning of this policy.

Right to erasure (“the right to be forgotten”)

Under certain circumstances, you have the right to request the deletion of your personal data. It's important to note that we not only process personal data for our own purposes but also act as data processors on behalf of venues. If you request the deletion of your personal data, we will address the request in relation to our own processing. However, if you also want a venue to stop processing your personal data, you must directly contact the venue.

In detail, you have the right, and we have the obligation, to delete your personal data without undue delay if any of the following conditions apply:

Personal data are no longer necessary for the purposes for which they were collected or processed.
You object to the processing pursuant to Article 21.1 of the GDPR, and there are no legitimate reasons for the processing that outweigh your reasons, or you object to the processing in accordance with Article 21.2 of the GDPR.
Personal data have been unlawfully processed.
Personal data must be deleted to fulfill a legal obligation under EU law or any applicable national law to which we are subject.

In cases where we have made your personal data public and are required to delete it, we will take reasonable steps, including technical measures, to inform other data controllers of your request and that they should delete any links to, or copies or reproductions of, specific personal data.

Please be aware that our obligation to delete and notify does not apply to the extent processing is necessary for the following reasons:

To exercise the right to freedom of expression and information.
To fulfill legal obligations under EU law or applicable national law to which we are subject.
To be able to establish, assert, or defend legal claims.

We will delete your personal data upon your request, provided that we do not have an obligation to retain the personal data in accordance with applicable laws and regulations.

We will notify each recipient with whom the personal data has been shared of any deletion that has taken place, as described above, unless this proves to be impossible or entails a disproportionate effort. For information about these recipients, you are welcome to contact us. Our contact information is provided at the beginning of this privacy policy.

Right to restrict processing

Under certain circumstances, you also have the right to request that we restrict our processing of your personal data.

In detail, this right applies if:

You dispute the accuracy of the information (but only for the time necessary to verify).
The processing is unlawful, and you oppose the deletion of personal data, instead requesting a restriction on the use of the data.
You need the personal data to assert or defend legal claims, even though we no longer need the data for our purposes.
You have objected to the processing in accordance with Article 21.1 of the GDPR, and we have not yet assessed whether our legitimate interest in the processing outweighs your legitimate reason for restricting the processing of your personal data.

If the processing referred to above is restricted, such personal data (excluding storage) may only be processed with your consent or to establish, assert, or defend legal claims, or to protect the rights of any other persons, or for reasons of public interest. Furthermore, we will notify you before ceasing to restrict any processing.

We will also notify each recipient to whom the personal data has been disclosed of any restriction on processing as described above unless it proves impossible or entails a disproportionate effort. If you want information about these recipients, you are welcome to contact us. Our contact information is provided at the beginning of this privacy policy.

Right to data portability

Under certain circumstances, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format and, where technically feasible, have it transferred to another company (known as "data portability").

In detail, the right to data portability applies to personal data that you have provided to us in a structured, widely used, and machine-readable format, provided that the processing is based on the legal basis of the performance of a contract (GDPR, Article 6.1 b), and the processing is automated.

It's important to note that exercising the right to data portability does not impact the application of Article 17 of the GDPR, which does not apply to processing necessary for the performance of a task of general interest or part of the exercise of authority performed by us.

Furthermore, your right to data portability must not adversely affect the rights and freedoms of others.

Right to withdraw your consent and object to processing

You have the right to object to our processing of your personal data when the processing is based on the legal basis of "legitimate interest," and we will always consider your objection. Additionally, you have the right to withdraw any consent you have given us, either partially or completely. For instance, you can withdraw consent for the use of your data in marketing and profiling activities, such as sending newsletters, surveys, or providing customized suggestions. More information on this is available in the charts above.

In detail, if you object, we may cease processing your personal data unless we can demonstrate compelling legitimate reasons for the processing that outweigh your interests, rights, and freedoms, or if the processing is necessary for the determination, exercise, or defense of legal claims.

Right to lodge a complaint with a supervisory authority

You always have the right to lodge a complaint with a supervisory authority, and you may do so in the EMEA member state where you live, work, or where an alleged infringement of applicable data protection laws has occurred.

Regarding the balancing of interests assessments when processing personal data based on the legal basis of "legitimate interests," as stated above, we conduct a thorough assessment to ensure that our legitimate interest for the processing outweighs other concerns. This assessment is carried out diligently, with the aim of achieving a fair balance.

If you seek more information about any aspect of how we process your data or wish to exercise any of your rights, please feel free to contact us. Our contact information can be found at the beginning of this privacy policy.

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