Privacy Policy of the "Palms Beach Club"
1. Terms- "Policy" – this privacy policy (personal data processing policy);
- "Club" – "Palms Beach Club", located at: Latvia, Riga, Mukupurva 1C;
- "Website" – the Club's website with the domain name www.palms.lv;
- "Mobile Application" – the mobile application of the "Palms Beach Club" for mobile devices;
- "User" ("Users") – a user of the Website and/or Mobile Application, as well as an individual using the services of the Club based on a one-day (guest) contract or long-term contract (membership card);
- "Personal Data" (or "Personal Information") – any information about the User that allows for the direct or indirect identification of the individual;
- "Services" – any functional capabilities of the Website and Mobile Application that enable the User to interact with the Club by providing their personal data. The Services may include, among other things: ordering and freezing a membership card, signing up for a trial session, booking a personal training, registering for an event, personal account;
- "Services" – refers to the services provided by the Club.
2. General Provisions2.1. This Policy applies to any personal data that the Club may obtain about the User while using the Website, Mobile Application, during the conclusion and execution of any contracts between the Club and the User, or contracts where the User is a beneficiary—regardless of whether such personal data is collected through the Website, Mobile Application, or during personal interaction between the Club's staff and the User, including filling out documents at the Club's premises.
2.2. The processing of the User’s personal data, including data obtained while using the Website and/or Mobile Application, is organized and carried out by the Club.
2.3. This Policy is an appendix to the Club’s Rules. When concluding contracts with the Club, as well as contracts where the User is a beneficiary, the User is required to familiarize themselves with this Privacy Policy in the manner prescribed for reviewing the Club’s Rules.
2.4. The use of the Website, Mobile Application, or Club services constitutes the User’s unconditional agreement with this Policy and the specified purposes, terms, methods, and conditions of personal data processing. If the User does not agree with these conditions, they must refrain from using the Mobile Application, Website, and Club services.
3. User’s Personal Information Processed by the Club3.1. When the User utilizes the Mobile Application, Website, or Club services, the Club may process the following types of personal information:
(a)
Personal information provided by the User independently during the installation of the Mobile Application on their devices, while using the services, when entering into contracts with the Club as a party or beneficiary, and in the course of executing these contracts. Information that is mandatory for submission is specifically marked. Other information is provided at the User’s discretion.
(b)
Data automatically transmitted to the Club during the use of the Website and Mobile Application via the software installed on the User’s device, including IP address, cookie data, information about the User’s browser (or other software used to access the Services), technical specifications of the hardware and software used by the User, date and time of access to the services, addresses of requested pages, and other similar information.
3.2. When using the Website and Mobile Application, the Club does not verify the accuracy of the personal information provided by the User and has no ability to assess their legal capacity. However, the Club assumes that the User provides truthful and sufficient personal information and maintains its accuracy.
4. Purposes, Duration, and Methods of Processing User’s Personal Information4.1. The Club collects only the personal information necessary to provide services to the User, ensure the operation of the Mobile Application, fulfill contracts with the User, and conclude such contracts at the User’s initiative or where the User is a beneficiary.
4.2. The Club stores and processes collected information only for the periods necessary to carry out the purposes listed in
Section 4.3, except where a different mandatory data retention period is established by law.
4.3. The Club processes the User’s personal information for the following purposes:
- 4.3.1. Identifying the User as a party or beneficiary within the Club’s services and contracts, fulfilling such contracts, ensuring the User’s rights under these contracts, and concluding contracts at the User’s initiative.
- 4.3.2. Communicating with the User, including sending notifications, requests, and information related to service usage, service provision, contract conclusion and execution, as well as handling User requests and applications.
- 4.3.3. Improving service and product quality, enhancing ease of use, developing new services, and introducing new offerings.
- 4.3.4. Providing targeted advertising materials from the Club and its partners, including promotions, events, new services, and offers (only with the User’s separate consent).
- 4.3.5. Conducting statistical and other research using anonymized data.
4.4. The Club processes personal data using a mixed approach (both automated and non-automated methods).
4.5. The Club does not conduct cross-border transfers of the User’s personal information.
4.6. When reviewing this Policy before using the services, the User may consent to their personal data being used for targeted advertising materials (
Section 4.3.4) and select a preferred communication method (SMS, email). If such consent is not given, personal data obtained through service usage will not be processed for this purpose. The User may withdraw this consent, in which case the Club must cease using the User’s data for advertising purposes. Users can also modify their preferences regarding promotional materials in their
Personal Account on the Website or Mobile Application (if available). Regardless of the initial consent, the User can enable or disable
push notifications for promotional messages at any time through the Mobile Application settings.
4.7. If the Club collects special categories of personal data for establishing and exercising the User’s rights under contracts, such data may not be processed for any other purposes unless the User provides explicit written consent.
4. Purposes, Duration, and Methods of Processing User’s Personal Information4.1. The Club collects only the personal information necessary to provide services to the User, ensure the operation of the Mobile Application, fulfill contracts with the User, and conclude such contracts at the User’s initiative or where the User is a beneficiary.
4.2. The Club stores and processes collected information only for the periods necessary to carry out the purposes listed in
Section 4.3, except where a different mandatory data retention period is established by law.
4.3. The Club processes the User’s personal information for the following purposes:
- 4.3.1. Identifying the User as a party or beneficiary within the Club’s services and contracts, fulfilling such contracts, ensuring the User’s rights under these contracts, and concluding contracts at the User’s initiative.
- 4.3.2. Communicating with the User, including sending notifications, requests, and information related to service usage, service provision, contract conclusion and execution, as well as handling User requests and applications.
- 4.3.3. Improving service and product quality, enhancing ease of use, developing new services, and introducing new offerings.
- 4.3.4. Providing targeted advertising materials from the Club and its partners, including promotions, events, new services, and offers (only with the User’s separate consent).
- 4.3.5. Conducting statistical and other research using anonymized data.
4.4. The Club processes personal data using a mixed approach (both automated and non-automated methods).
4.5. The Club does not conduct cross-border transfers of the User’s personal information.
4.6. When reviewing this Policy before using the services, the User may consent to their personal data being used for targeted advertising materials (
Section 4.3.4) and select a preferred communication method (SMS, email). If such consent is not given, personal data obtained through service usage will not be processed for this purpose. The User may withdraw this consent, in which case the Club must cease using the User’s data for advertising purposes. Users can also modify their preferences regarding promotional materials in their
Personal Account on the Website or Mobile Application (if available). Regardless of the initial consent, the User can enable or disable
push notifications for promotional messages at any time through the Mobile Application settings.
4.7. If the Club collects special categories of personal data for establishing and exercising the User’s rights under contracts, such data may not be processed for any other purposes unless the User provides explicit written consent.
5. Conditions for Processing and Transferring User’s Personal Information
5.1. The confidentiality of the User’s personal information is maintained, and the Club is obligated not to disclose or distribute personal data to third parties without the User’s consent. This confidentiality condition does not apply in cases where the User has voluntarily made their personal information publicly available.
5.2. By reviewing this Policy, the User agrees that the Club has the right to transfer the User’s personal information to third parties in the following cases:
5.2.1. The transfer is necessary to enable the User to use the Website or Mobile Application, fulfill a specific contract with the User, or a contract in which the User is a beneficiary.
5.2.2. The transfer occurs as part of a sale or other transfer of the business (in whole or in part), in which case the acquiring party assumes all obligations to comply with the conditions of this Policy regarding the received personal information.
5.2.3. The transfer is necessary to protect the rights and legal interests of the Club or third parties when the User violates this Policy, service usage terms, or contracts with the Club. This applies unless applicable law requires separate written consent from the User for such actions. However, under no circumstances may the Club transfer to third parties any personal data classified by law as special categories for these purposes.
5.2.4. As a result of processing the User’s personal information through anonymization, anonymized statistical data is generated and transferred to third parties for research, work, or services performed on behalf of the Club.
5.3. Without the User’s consent, the transfer of their personal data is only possible in cases prescribed by applicable Russian or other relevant laws and in accordance with the legally established procedure.
6. Modification, Clarification, Blocking, and Deletion of Personal Information. Mandatory Data Retention and Processing
6.1. The User has the right, in the form, manner, and under the conditions established by law, to submit a request to the Club for a list of personal data being processed. The User may also request correction, blocking, or deletion of such data if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the declared processing purpose. Additionally, the User may take measures provided by law to protect their rights.
6.2. If the User has a "Personal Account" on the Website and/or in the Mobile Application, they may modify (update, supplement) their provided personal information at any time using the personal data editing function in the "Personal Data" section.
6.3. The User may also delete personal information stored in the "Personal Account" on the Website or Mobile Application by using the "Delete Account" function in the "Personal Account" section. Deleting the account will result in the inability to continue using the "Personal Account" section.
6.4. The rights outlined in Sections 6.1 – 6.3 of this Policy may be restricted in accordance with legal requirements. In particular, such restrictions may require the Club to retain modified or deleted User information for a period established by law and to provide such information to an authorized state body as required by law. Processing of the User's personal data during the term of their contract with the Club (or a contract concluded in the User’s interest) may be carried out without separate User consent and may continue after consent is withdrawn for the period necessary to fulfill the relevant contract.
6.5. Modifying or deleting personal information in the "Personal Account" section of the Website and/or Mobile Application does not automatically update or erase personal data provided to the Club by other means. Discrepancies between personal data provided by the User through different channels may complicate the fulfillment of contracts between the User and the Club (or contracts concluded in the User’s interest). If such discrepancies are identified, the Club will contact the User for clarification and confirmation.
7. Processing of Personal Information Using Cookies and Counters
7.1. Cookies transmitted by the Club to the User’s device and received from the User’s device may be used by the Club to provide personalized information, target advertising displayed to the User, conduct statistical and research activities, and improve the Website’s functionality.
7.2. The User acknowledges that the equipment and software used to access websites may have features that allow the prohibition of operations with cookies (for all websites or specific ones) and the deletion of previously received cookies. Information on how to disable or delete cookies can be found in the help sections of the User’s Internet browser.
7.3. The Club may establish that access to certain services is possible only if the User enables the reception and transmission of cookies.
7.4. The structure, content, and technical specifications of cookies are determined by the Club and may be modified without prior notice to the User.
7.5. Counters placed by the Club on the Website may be used to analyze the User’s cookies, collect and process statistical data on Website usage, and ensure the functionality of the Website or its specific features. The technical specifications of these counters are determined by the Club and may be changed without prior notice to the User.
8. Measures for Protecting User’s Personal Information
8.1. The Club takes necessary and sufficient legal, organizational, and technical measures to comply with legal requirements and protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions by third parties.
8.2. In addition to the above measures, the Club implements technical measures to prevent unauthorized access to systems storing personal data, ensures data backup, protects data storage media, and enforces other necessary security measures.
9. Changes to the Privacy Policy and Governing Law
9.1. The Club reserves the right to amend this Privacy Policy. The latest version will indicate the date of the last update. Unless otherwise specified in the updated Policy, the new version takes effect:
(a) For the processing of personal data when using the Website and Mobile Application—from the moment it is published on the Website and in the Mobile Application (and for cases where User consent is required by law for new purposes, methods, or conditions of data processing—from the moment the User reviews the updated Policy).
(b) For other cases of personal data processing—from the moment the User reviews the updated Policy at the Club’s reception with the on-duty administrator.
9.2. This Policy and the relationship between the User and the Club regarding the application of the Privacy Policy shall be governed by the laws of the Republic of Latvia.
10. Feedback, Questions, and Suggestions
10.1. The User may send any suggestions or questions regarding this Policy to the Club via email at
info@palms.lv or by mail to the Club’s address:
Latvia, Riga, Mukupurva 1C.