Personal Data Protection Policy
Published on: September 07, 2026
This Policy explains the type of personal information Gym Breeze collects from you, the way we handle it and the rights that you, as our customer and a data subject, have in relation with the collection and processing of your personal data.
DEFINITIONS:
Data Controller: Adjara Group LLC (I/C: 404676169, legal address: Kostava 14, Tbilisi, Georgia), a legal entity who determines purposes and means of Your personal data processing and who processes Your personal data (hereinafter referred to as “Gym Breeze” or “We”, “Us”, “Our”)
Personal Data or Personal Information: information We collect from You that enables Us to an identified or identifiable individual.
Tournament: Gym Breeze Annual Tournament held on September 17 till September 27, 2026.
You: Participant of the Tournament of legal age (18 years or old).
We collect Your Personal Data from the following channels/sources:
1. By registering on this Website and purchasing the Tournament ticket;
2. By indicating the information on the coplayer on the registration stage.
(the “Sources of Data Collection” or the “Activities” in plural / the “Activity” in singular).
Therefore, upon filling out the registration form on Our Website, You are obligated to get acquainted with this Policy displayed on Our Website and any amendments made hereto.
If You have any questions or concerns about privacy after reviewing this Privacy Policy, please address Us on the contact details indicated in Section 8 of this Privacy Policy.
1. PERSONAL INFORMATION WE COLLECT FROM YOU
Depending on the Activity You pursue, We may collect and process different Personal Data. Herein below, please, find the detailed list of what We are collecting from You:
1. In case of filling out the registration form for the purposes of participating in the Tournament, We collect the following information about you and your co-player: name, surname, electronic mail address, mobile number and gender (if the Player selects B and/or C level of the Tournament);
2. In the event of participating in the Tournament, We may take various photos and video-recordings of such events which may include You and by accepting this Privacy Policy You explicitly state that You shall have no claim or any complaint regarding such photo/video recordings and their publication on various social media platforms and/or on Our Website;
3. The data of the participants (name and surname) going through to the next stage of and/or winning the Tournament may be published on its social media platforms and its Webiste / App by Gym Breeze and by accepting this Privacy Policy You explicitly state that You shall have no claim or any complaint regarding publishing.
We do not collect bank card details or requisites for payment. Respectively, We do not have access to this information. You are transferred to the third party’s (payment service provider) page for making the payment and data is collected and processed in respective with the third party’s policy.
2. PURPOSE OF COLLECTING AND PROCESSING OF THE PERSONAL DATA
We collect and process Your Personal Data only to the extent of and limited to the following purposes:
1. For your participation in the Tournament;
2. To ensure all the adequate and necessary safety measures when You access our padel courts as customers;
3. To meet corporate governance and statutory managerial/analytical/legal/financial/tax requirements as set out under respective corporate governance rules within the group of companies to which Data Controller belongs and as provided under the laws of Georgia;
4. To conduct direct marketing activities (only and in case if Your respective explicit consent on such activity is provided to Us);
5. Protecting legal interests of Gym Breeze;
6. Any other legitimate interest of Gym Breeze as provided under the laws of Georgia.
3. THIRD PARTY CONTRACTORS
Gym Breeze is the sole owner and operator of the Website and does not transfer data to the third parties, except those listed herein below:
1. Payment Service Providers – We have third party contractor for providing payment services. They collect the data for the purposes of payment. We do not collect bank card details or requisites for payment. Respectively, We do not have access to this information. You are transferred to the third party’s (payment service provider contractor) page for making the payment and data is collected and processed in respective with the third party’s policy.
2. Our affiliates – Gym Breeze’s affiliates receive the data for processing it within the scope of services provided to Gym Breeze (managerial or analytical services) as envisaged in sub-paragraph “c” of Section 2 above as per respective corporate governance policies within the group of companies to which Gym Breeze belongs.
Affiliate implies entities affiliated with/related to Us, i.e. any entity and/or person that is directly or indirectly controlled by Us, is under common control with Us or is controlled together with Us by other affiliated entity in consideration of common business interests. For the purposes of this Section, term “control” means possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity/person, whether through the ownership or control of interests or voting securities, by contract or otherwise.
4. GROUNDS FOR PROCESSING PERSONAL INFORMATION
We process Your Personal Data on the following grounds:
1. In case if You provide consent on such processing;
2. If We need processing for the purposes of your participation in the Tournament;
3. If We need processing for meeting internal policies and procedures within the group of companies to which We belong;
4. If there are statutory grounds for processing as envisioned under the laws of Georgia.
5. STORAGE DURATION AND SECURITY
We shall keep Your Data to the extent and for the period of what is necessary to achieve the purposes of collecting and processing Personal Data, indicated in Section 2 of this Privacy Policy. We routinely erase and destroy such data or keep it in unidentifiable and depersonalized manner for our analytical and statistical purposes, if the purpose of its processing no longer exits and minimize the Personal Data collected by Us only to the extent which is necessary to store and process for any then current and valid purpose.
We take all reasonable measures for safety and security of Personal Data and strictly follow the persons, who have access to this Data within the purposes laid down in Section 2 herein above. However, we bear no responsibility for non-sanctioned intrusions and access to the Data by the third parties.
6. YOUR RIGHTS AND OBLIGATIONS
Under this Privacy Policy, You, as the data subject, are entitled to address the following rights with respect to Your Personal Data at any time and without any costs/charges from Our side:
1. which Personal Data concerning You, are being processed, as well as the grounds for and the purpose of the processing;
2. the source from which the Personal Data were collected/obtained;
3. the period for which the Data will be stored and, if no specific period can be determined, the criteria used to determine that period;
4. the legal basis and purposes of the data transfer, as well as the appropriate data protection safeguards if the data are transferred to another state;
5. the categories of recipients, including information on the ground for and purpose of the transfer, if the data are transferred to a third party;
6. the decision made as a result of automated processing, including profiling (if carried out), and the logic involved in making such a decision, as well as its impact on the processing and the expected results of the processing;
7. To request the transfer of Your Personal Data collected and processed by Us to other third-parties;
8. To withdraw Your consent on processing Your Personal Data by Us; and/or
9. To appeal to the Personal Data Protection Service (please, refer to the contact details indicated below in section 12 of this Privacy Policy) or common courts of Georgia.
You also have the right to request correction of erroneous Personal Data, renewing the Data, the right to request suspension of Data processing, erasure of Data or destruction. Your request should be satisfied within 10 business days. We retain the right of refusal, if Your request contradicts with our legitimate lawful interests, public interests, legal obligations or requirements of applicable law. Our decisions on refusal(s) mentioned above will be served with respective justification and the explanation on the ways of its appeal.
Please also note, that if You request deletion, erasure or destruction of the Data that is necessary for providing Our services, We will be unable to continue rendering Our services to You.
If You would like to submit Your request with any of the foregoing inquiries regarding Your Personal Data, please address us on the contact information indicated in Section 8 of this Privacy Policy.
You are liable for any loss or damage inflicted to Us or third party for submitting erroneous, inaccurate or incomplete Information. Please note, that when You provide Us with Your friend’s mobile number who are not registered customers in Our app for the purposes of sharing the payment, We act on the assumption that You have all necessary consents for sharing this data with Us. You indemnify and hold Us harmless from any and all claims from their side in relation with data sharing. We once again note that if Your friend is not registered customer with Us and has not expressed consent on direct marketing activities, We do not process such friend’s data for the purposes of direct marketing.
7. APPLICABLE LAW
Gym Breeze application, this Privacy Policy and any document / form which we might further execute on the basis of this Privacy Policy, are subject to the applicable laws of Georgia.
8. CONTACT INFORMATION
For any questions, claims, requests or other inquiries, please contact Us here:
Adjara Group LLC (I/C 404676169)
Postal Address: 14 Kostava Street, Tbilisi, Georgia
E-mail address: pdsupport@adjaragroup.com