Политика конфиденциальности (EU / GDPR / App Store)

1. Who processes data

Data Controller:

Spordiklubi BARS MTÜ
Reg. nr: 80596461
Maakri tn 44-4, Tallinn 10145, Estonia
info@barsswim.ee

Data Processor:

Gleb Tsyganov

2. What data we collect

When using the barsswim application, the following data may be processed:

• name and personal code of the child (if provided in the contract)
• date of birth
• name and contact details of the parent (phone, email)
• contract data (number, status)
• internal statistics: attendance, skills, student achievements
• device technical data and application usage analytics

Medical data is not collected.

3. Legal basis for processing (GDPR)

Personal data is processed on the basis of:

• Performance of a contract with the parent (Art. 6(1)(b) GDPR)
• Legitimate interest of the club — maintaining records of training and results (Art. 6(1)(f) GDPR)

4. Why we use data

Data is used for:

• maintaining records of attendance and student progress
• displaying achievements in the application
• contacting parents regarding training matters
• improving application performance and analytics

5. Third-party services

For data storage and processing, the following are used:

• Supabase — database and authentication
• analytics services (for example, Firebase Analytics, if connected)

Data transfer is carried out only for technical processing and does not give third-party services the right to use data for their own purposes.

6. Retention period

Data is stored for the duration of the contract.

After termination of the contract, data may be retained in the archive for up to 3 years to protect the rights of the club (for example, in case of disputes).

7. Transfer of data outside the EU

Transfer of data outside the EU may only be carried out if there are legal guarantees (Standard Contractual Clauses or equivalents under GDPR).

8. User rights

The user (parent) has the right to:

• request access to their data
• request correction of inaccurate data
• request deletion of data (if this does not contradict legal grounds for storage)
• file a complaint with the supervisory authority (Andmekaitse Inspektsioon, Estonia)

Requests should be sent to: info@barsswim.ee

9. Data security

We apply technical and organizational measures to protect data from unauthorized access, loss, alteration and destruction.

10. Policy changes

The policy may be updated. The current version is published in the barsswim application.