Privacy Policy

1Data Controller

Kempes BV, trading as GARRINCHA (www.garrincha.be), a company registered in Belgium, is the data controller responsible for your personal data processed through the GARRINCHA Connect app.

Registered office: Kortrijksesteenweg 1166, 9051 Gent, Belgium · Company (KBO/BCE) & VAT number: BE 0635.670.989

2Data We Collect

Account data

• Name, username, email address, phone number (optional), and profile photo
• Date of birth (to verify age eligibility) and gender (optional)
• City, court position, playing level, and bio

Activity data

• Match results, ELO history, challenge records
• Posts, stories, reels, and comments you create
• Groups you join and messages you send
• GARRINCHA Points earned and rewards redeemed

Technical data

• Device type, operating system, and app version
• IP address, and precise location with your permission (to show your nearest club, check you in automatically, and find nearby players)
• App usage patterns and crash reports

Payment data

Payment processing is handled entirely by our payment provider. GARRINCHA does not store card numbers or full payment details. We retain only subscription status and billing history.

3Legal Basis for Processing (GDPR Art. 6)

• Contract (Art. 6.1.b) — to create your account and deliver the Service
• Legitimate interests (Art. 6.1.f) — to improve the app, ensure security, and detect fraud
• Consent (Art. 6.1.a) — for marketing communications and location features
• Legal obligation (Art. 6.1.c) — to comply with Belgian and EU law

4How We Use Your Data

• Provide, maintain, and improve the App and its features
• Display your profile, posts, and match history to other users (per your privacy settings)
• Show your nearest club, check you in automatically, and match you with nearby players — using your precise location, with your permission
• Calculate your ELO rating and leaderboard ranking
• Deliver loyalty rewards and notify you of Points activity
• Process subscription payments and send receipts
• Send important account and service notifications
• Detect, investigate, and prevent fraud, abuse, and policy violations
• Comply with legal obligations and respond to lawful requests

5Data Sharing

We do not sell your personal data. We share data only in the following circumstances:

• Other users — profile, skill ratings, match history, and posts, subject to your privacy settings
• GARRINCHA centres — check-in status and loyalty Points activity relevant to their centre
• Playtomic — we receive ELO and match data from Playtomic when you connect your account; we do not send data to Playtomic
• Payment provider — for payment processing; governed by their own privacy policy
• Cloud infrastructure providers — for secure data hosting within the EU
• Law enforcement — only when legally required by a competent Belgian or EU authority

6International Data Transfers

Your data is stored and processed within the European Economic Area (EEA). Where any transfer outside the EEA is necessary, we ensure it is protected by appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission.

7Data Retention

• Active account data — retained for the duration of your account
• Account data after deletion — erased within 30 days, except where required by law
• Payment records — retained for 7 years to comply with Belgian accounting law
• Usage logs — anonymised and retained for up to 12 months for analytics

8Your Rights Under GDPR

As a data subject in the EU/EEA, you have the following rights:

• Right of access — request a copy of your personal data (Art. 15)
• Right to rectification — correct inaccurate or incomplete data (Art. 16)
• Right to erasure — “right to be forgotten” (Art. 17)
• Right to restriction — limit how we process your data (Art. 18)
• Right to data portability — receive your data in a machine-readable format (Art. 20)
• Right to object — object to processing based on legitimate interests (Art. 21)
• Right to withdraw consent — at any time, without affecting prior processing

To exercise any right, email privacy@garrincha.be. We will respond within 30 days. You can also delete your account and data yourself — see Delete your account.

9Cookies and Tracking

The App uses essential cookies and local storage to maintain your session and preferences. We do not use third-party advertising cookies.

Analytics are collected in aggregate, anonymised form to understand how the App is used. You may opt out of analytics in Settings → Privacy.

10Children's Privacy

The App is not directed at children under 16. We do not knowingly collect personal data from children under 16. If you believe a child under 16 has provided us with personal data, please contact privacy@garrincha.be and we will delete it promptly.

11Security

We implement industry-standard technical and organisational measures to protect your data, including encryption in transit (TLS) and at rest, access controls, and regular security reviews.

In the event of a personal data breach that poses a risk to your rights, we will notify the APD/GBA within 72 hours and notify you without undue delay, as required by GDPR Art. 33–34.

12Changes to This Policy

We may update this Privacy Policy to reflect changes in the law or our practices. We will notify you via the App or email at least 14 days before material changes take effect. The latest version is always available at this page.

Data requests: privacy@garrincha.be · GARRINCHA · www.garrincha.be · Belgium