Last updated: [date]

1. Who is responsible for your data
The controller is Sports Evolution Sàrl-S, 5, rue de la Gare, L-8325 Capellen, Luxembourg, RCS [number] (“Sports Evolution”, “we”). Contact for all data protection questions: info@sportsevolution.lu

2. Whose data we process
We process data of parents/legal guardians who register a child, of the participating children (aged 8–15), of emergency contacts named by parents, and of visitors to our website.

3. What data we process, why, and on what legal basis

Registration, payment and confirmation
Data: parent’s name, email, phone and address if requested; child’s name, date of birth, sport and camp, selected add-ons (including clothing size); payment data (processed by Stripe; we do not store card numbers).
Legal basis: performance of the contract, Art. 6(1)(b) GDPR.

Safety and wellbeing of the child during the camp
Data: allergies, medical conditions, medication, emergency contact.
Legal basis: explicit consent of the parent, Art. 9(2)(a) and 6(1)(a) GDPR. The parent provides this data voluntarily. Without it we may not be able to admit the child.

Meals
Data: allergy and dietary information, passed to the caterer.
Legal basis: explicit consent, Art. 9(2)(a) GDPR.

Orders of add-ons
Data: sizes and quantities, without names of children.
Legal basis: performance of the contract, Art. 6(1)(b) GDPR.

Communication with parents
Data: confirmation emails, practical information, WhatsApp groups.
Legal basis: performance of the contract, Art. 6(1)(b) GDPR.

Photos and videos in the camp’s private WhatsApp group
Data: photos and videos of participants.
Legal basis: consent, Art. 6(1)(a) GDPR, given at registration.

Public use of photos and videos (website, Instagram, TikTok, posters, flyers)
Data: photos and videos of participants.
Legal basis: separate, optional consent, Art. 6(1)(a) GDPR.

Accounting, tax and legal obligations
Data: invoices, payment records, refunds.
Legal basis: legal obligation, Art. 6(1)(c) GDPR.

Handling requests, complaints and legal claims
Data: correspondence, booking history.
Legal basis: legitimate interest, Art. 6(1)(f) GDPR.

Operation and security of the website
Data: technical data (IP address, browser, device).
Legal basis: legitimate interest, Art. 6(1)(f) GDPR.

4. Consent and withdrawal
Where we rely on consent, you can withdraw it at any time by email to info@sportsevolution.lu. Withdrawal applies to future processing and does not affect earlier lawful processing. Consent for the public use of photos is optional and separate from the registration.

5. Who receives your data

We do not sell personal data. We share it only as needed:

• Our coaches and camp staff (safety, emergency contacts, medical information and allergies).

• Our caterer [name] (allergy and dietary information, only as needed for meals).

• Add-on suppliers, who receive only quantities and sizes, never children’s names or contact details.

• Emergency services and doctors, where needed to protect the child.

• Authorities, accountants and legal advisors, where required by law.

Service providers that process data on our behalf under data processing agreements:

• Framer: website and booking form.

• Stripe: payment processing and refunds.

• Google (Sheets, Drive): registration list and order preparation.

• WhatsApp (Meta): camp groups, communication and photos.

• [Email provider]: confirmations and practical information.

• Anthropic (Claude): AI assistant used for internal administration. We use it only with the minimum data necessary.

6. Transfers outside the EU/EEA
Some providers (for example Stripe, Google, Meta/WhatsApp, Framer, Anthropic) may process data outside the EU/EEA, in particular in the USA. In this case we rely on the European Commission’s adequacy decision or on standard contractual clauses and equivalent safeguards, as applicable to each provider.

7. How long we keep your data

• Registration, medical and allergy data of children: deleted [X months] after the end of the camp.

• Photos and videos in the WhatsApp group: until the group is closed or deleted, at the latest [X months] after the camp.

• Photos published on the website or social media: until you withdraw consent or the material is removed.

• Accounting and payment records: for the period required by Luxembourg law (generally 10 years).

• Correspondence: [X months] after the request is closed.

8. Your rights
You may request access, correction, deletion, restriction of processing, data portability, and object to processing based on legitimate interest. You may withdraw consent at any time. Write to info@sportsevolution.lu. We answer within one month. You have the right to lodge a complaint with the Commission nationale pour la protection des données (CNPD), 15, boulevard du Jazz, L-4370 Belvaux, Luxembourg, www.cnpd.lu.

9. Data security
We limit access to children’s data to the staff who need it, we do not publish it, and we use secure providers and access controls. Medical and allergy information is used only for the child’s safety.

10. Cookies and website data
Our Site is hosted by Framer. [Describe cookies and analytics used, or state that only technically necessary cookies are used.]

11. Changes
We may update this Privacy Policy. The current version is published on this page with its date.

12. Contact
Sports Evolution Sàrl-S, 5, rue de la Gare, L-8325 Capellen, Luxembourg
Email: info@sportsevolution.lu