Privacy Policy

1. Data Controller

Kemin SamBO ry (registry ID: pending) is the data controller for the processing of personal data collected through the website kemi-sambo.fun and in connection with club membership, event registrations, and training attendance. The club is registered in Kemi, Finland, and operates in accordance with Finnish data protection legislation and the EU General Data Protection Regulation (GDPR).

Address: Rytikarin, Kemi, Finland
Email: [email protected]

2. What Personal Data We Collect

We collect the following categories of personal data:

• Identity Data: Full name, date of birth, gender, and a profile photograph (optional).
• Contact Data: Email address, phone number, and residential address.
• Membership Data: Membership plan type, start and end dates, payment history, and training attendance records.
• Medical Data: (Collected separately via paper forms) Health conditions relevant to safe training participation, such as injuries, allergies, and chronic conditions.
• Technical Data: IP address, browser type, device information, and browsing behavior on our website via cookies and similar technologies.
• Communication Data: Messages sent through our contact form, WhatsApp inquiries, and email correspondence.

3. How We Collect Your Data

We collect data through the following means:

• Membership application forms (online and paper-based)
• Event registration forms
• Contact form submissions on the website
• WhatsApp messages and email correspondence
• Website analytics (cookies and page interaction data)
• Training attendance tracking

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Performance of a contract (GDPR Art. 6(1)(b)): Processing necessary for membership administration, training scheduling, and event participation.
• Legitimate interests (GDPR Art. 6(1)(f)): Club communications, training attendance tracking, and safety management.
• Consent (GDPR Art. 6(1)(a)): Newsletter subscriptions, photo/video publication permissions, and cookie consent.
• Legal obligation (GDPR Art. 6(1)(c)): Retention of financial records as required by Finnish accounting law.

5. How We Use Your Data

We use your personal data for the following purposes:

• Managing club memberships and training registrations
• Organizing events and competitions
• Communicating training schedule changes and club announcements
• Processing payments and membership fees
• Maintaining training attendance records
• Ensuring member safety during training
• Improving our website and services
• Complying with legal and regulatory obligations

6. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

• Membership data: Retained for the duration of membership plus 2 years after termination for club records.
• Financial records: Retained for 6 years as required by Finnish accounting law.
• Contact form inquiries: Retained for 1 year after the last correspondence.
• Website analytics data: Retained for 26 months (Google Analytics default retention period).
• Medical data: Retained for the duration of membership and securely destroyed upon termination.

7. Data Sharing and Third Parties

We do not sell your personal data to third parties. We may share data with the following categories of recipients:

• Service providers: Website hosting (Vercel Inc.), email services, payment processors, and analytics providers (Google Analytics).
• Sports governing bodies: FIAS (International SAMBO Federation) and the Finnish SAMBO Federation for competition registrations and athlete licensing.
• Legal authorities: When required by applicable law or to protect our legal rights.

8. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA) when using third-party services such as Vercel (US-based hosting) and Google Analytics. We ensure appropriate safeguards are in place through Standard Contractual Clauses (SCCs) and data processing agreements with our service providers.

9. Your Rights Under GDPR

As a data subject, you have the following rights:

• Right to access (Art. 15): Request a copy of the personal data we hold about you.
• Right to rectification (Art. 16): Request correction of inaccurate or incomplete data.
• Right to erasure (Art. 17): Request deletion of your data, subject to legal retention requirements.
• Right to restrict processing (Art. 18): Request limitation of data processing in certain circumstances.
• Right to data portability (Art. 20): Request a machine-readable copy of your data.
• Right to object (Art. 21): Object to processing based on legitimate interests or for direct marketing.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

10. Cookies

Our website uses essential cookies for functionality and analytics cookies to understand how visitors interact with our site. You can manage cookie preferences through your browser settings. Analytics data is anonymized where possible.

11. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include SSL/TLS encryption, secure server infrastructure, and access controls for administrative systems.

12. Changes to This Policy

We may update this privacy policy from time to time. Changes will be posted on this page with an updated revision date. Significant changes will be communicated to active members via email.

13. Contact and Complaints

For questions about this policy or to submit a data subject request, contact our data protection representative:

Kemin SamBO ry
Email: [email protected]
Address: Rytikarin, Kemi, Finland

You have the right to lodge a complaint with the Finnish Data Protection Ombudsman (Tietosuojavaltuutetun toimisto):
tietosuoja.fi