PRIVACY POLICY OF SIA "Ryabinin Camps" AND SIA "IFSA"

1. PURPOSE AND SCOPE OF THE PRIVACY POLICY

1.1 The purpose of the Privacy Policy of SIA "Ryabinin Camps" and SIA "IFSA" (hereinafter jointly referred to as the "Joint Controllers") is to inform clients, business partners, and website visitors about the processing and protection of personal data of individuals (hereinafter referred to as the "Data Subject"). The Policy defines what data may be processed, the purposes, and the legal basis for such processing in accordance with Regulation (EU) 2016/679 (GDPR).

1.2 The Policy applies to the processing of personal data regardless of the form in which the Data Subject provides it to the Joint Controllers (on the website, electronically, via email, phone, or social media profiles).

1.3 The Joint Controllers reserve the right to amend the Policy at their discretion. The current version is always available on the website — https://ryabinincamps.com/en/.

2. CONTACT DETAILS OF THE JOINT CONTROLLERS

2.1 Regarding the data of platform users for online lessons, the Controller is SIA "Ryabinin Camps", registration number 40203433245, legal address: LIELA IELA 19 - 2, MARUPE, LV-2167.

2.2 Regarding the data of participants in offline figure skating camps, the Controller is SIA "IFSA", registration number 40203592502, legal address: LIELA IELA 19 - 2, MARUPE, LV-2167.

2.3 General contact details: Phone: +371 20237648, email: info@ryabinincamps.com.

3. CATEGORIES OF PERSONAL DATA AND PURPOSES OF PROCESSING

3.1 The Joint Controllers process data of the following categories of individuals:

• Clients (adult participants of camps and online lessons);
• Trainers (platform clients) providing online training services through the website;
• Minor camp participants (child athletes);
• Legal representatives of minors (parents, guardians, accompanying persons);
• Individuals subscribed to marketing newsletters or interacting with us on social media.

3.2 The Joint Controllers process the following categories of personal data:

• Identification data: name, surname, gender, date of birth;
• Contact data: address, phone number, email address;
• Data for contract execution: passport details (if necessary to arrange accommodation or transfers for "All Inclusive" and "Escort" packages);
• Trainer data: personal code (or date of birth) and residential address of trainers for concluding platform usage agreements;
• Bank details: processed separately. Payments for platform use and online lessons are processed by SIA "Ryabinin Camps"; payments for participation in offline training camps are processed by SIA "IFSA";
• Health data: medical certificates for clearance to participate in intensive sports training on and off the ice, as well as information regarding food allergies to ensure safe meals at the camps;
• Multimedia data: photos and videos of the training process on and off the ice.

3.3 Purposes of data processing:

• Providing services for the organization and execution of figure skating training camps and online lessons;
• Creation, administration, and support of user accounts and trainer accounts on the online platform;
• Ensuring participant safety (including verifying medical clearance for physical activity);
• Organizing accommodation, meals, and transfers within the selected service packages;
• Fulfilling the Joint Controllers' legal and accounting obligations;
• Creating marketing materials (publishing photos/videos from training sessions) to promote the sport.

4. LEGAL BASIS FOR DATA PROCESSING

• Performance of a contract: processing is necessary to provide booking, camp organization services, and platform usage.
• Consent: for sending marketing newsletters and publishing photo and video materials from training sessions.
• Legal obligation: for complying with accounting and tax legislation requirements of the Republic of Latvia.
• Protection of vital interests: processing health information (allergies, medical contraindications) is necessary to ensure the physical safety of the athletes.

5. PROCESSING OF MINORS' DATA

5.1 Because a significant portion of the camp participants are children, the Joint Controllers pay special attention to the protection of their data.

5.2 The collection and processing of personal data of individuals under the age of 18 (or other age of majority according to the Data Subject's jurisdiction) is carried out strictly with the explicit consent of their parents or legal representatives.

5.3 The legal representative filling out the application for a child's participation in the camps confirms their right to transfer the child's data to the Joint Controllers.

6. PHOTO AND VIDEO RECORDING AT CAMPS

6.1 As part of the training process, the Joint Controllers conduct photo and video recordings. These materials are used for the analytical review of jump and skating techniques and may also be published on the website and social media to demonstrate the training process.

6.2 We guarantee that the use of media materials will not violate the dignity and honor of the participants.

6.3 The Data Subject (or their legal representative) has the right to withdraw their consent to the publication of materials featuring them (or their child) at any time by writing to: info@ryabinincamps.com. Upon receipt of the request, the materials will be removed from public access within a reasonable time.

7. DATA TRANSFER, INCLUDING OUTSIDE THE EU/EEA

7.1 Data may be transferred to the Joint Controllers' trusted partners: accounting companies, hosting providers, as well as hotels, ice arenas, and transport companies involved in organizing the camps.

7.2 Because training camps are held in various locations (including Dubai and Asian countries), participants' personal data may be transferred to hosting organizations (hotels, arenas) outside the European Union and the European Economic Area. Such transfers are carried out strictly to the extent necessary to fulfill the service contract and organize the client's trip.

8. DATA RETENTION PERIOD

8.1 Data is retained for as long as necessary for the purposes for which it was collected, or for the period established by the laws of the Republic of Latvia (e.g., accounting documents — at least 5 years).

8.2 Contact data for marketing newsletters is retained until the Data Subject withdraws their consent.

9. SECURITY AND RIGHTS OF THE DATA SUBJECT

9.1 The Joint Controllers apply modern organizational and technical measures to protect data from unauthorized access, loss, or destruction.

9.2 The Data Subject has the right to:

• Request access to their data;
• Request correction of inaccurate data;
• Request deletion of data (the "right to be forgotten"), provided this does not contradict our legal obligations;
• Withdraw their consent to data processing at any time.

9.3 In case of a suspected rights violation, the Data Subject may file a complaint with the Joint Controllers (info@ryabinincamps.com) or with the Data State Inspectorate of the Republic of Latvia (Elijas iela 17, Rīga, LV-1050; info@dvi.gov.lv).

10. COOKIES AND THIRD-PARTY SERVICES

10.1 The website uses cookies (strictly necessary, functional, analytical, and advertising) to ensure operation, analyze traffic (Google Analytics), and provide personalized advertising.

10.2 Links to social media networks (Facebook, Instagram, YouTube) may be posted on the site. Interaction with these platforms is governed by their respective privacy policies. Users can manage cookie settings in their browsers.