Privacy Policy

1. ABOUT US AND THIS WEBSITE

In this section, we provide you with general information about us and this website. 

1.1 About. This privacy notice (the “Privacy Notice”) governs the processing of personal data collected from individual users (“you” and “your”) through the website https://snfighters.com and the related domain names (the “Website”). 

1.2 About the Website. The Website offers information about our services, the ‘SN Fighters’ team, and allows you to contact us by using a contact form.

1.3 Data controller.  The Website is owned and operated by FIGHTERS INTERNATIONAL having an address at Rue Vanderkindere 171 / 14, Brussels 1180, Belgium (“we,” “us,” and “our”). We act as a data controller with regard to the personal data that you submit through the Website. 

1.4 Third-party websites. The Privacy Notice does not cover any third-party websites, applications or software that integrate with the Website. We are not responsible for the privacy policies of websites to which the Website links. If you provide any information to such third parties different rules regarding the collection and use of your personal data may apply. You should contact these entities directly if you have any questions about their use of the data that they collect.

1.5 Children. The Website is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove the child’s personal data from our systems. 

1.6 Term and termination. This Privacy Notice enters into force on the date indicated at the top of the Privacy Notice and remains valid until terminated or updated by us.

1.7 Amendments. We may change or update this Privacy Notice occasionally to meet the requirements and standards in the field of data protection. Therefore, you are encouraged to frequently visit this page to be updated about the changes. If we need to amend the Privacy Notice, the amended version will be posted on this page and, if we have your email address, we will send you a notice about all the changes implemented by us. For significant material changes in the Privacy Notice or, where required by the applicable law, we may seek your consent.

2. WHAT DATA DO WE COLLECT?

In this section, we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically while you are using the Website, and how we communicate with you. 

2.1 Sources of personal data. We obtain your personal data from the following categories of sources:

• Directly from you. For example, if you contact us;
• Directly or indirectly through your activity on the Website. When you use the Website, we automatically collect technical information about your visits by means of cookies and analytics services; and
• From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us (for example, for analytics purposes).

2.2 Collection of personal data. We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that are necessary for your use of the Website. We do not use your personal data for any purposes that are different from the purposes for which you provided them. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use them, the legal bases on which we rely, and the time period of which we store them.

• Enquiries. When you contact us by email, we collect your name, email address, and any information that you decide to include in your message. When you contact us by using the contact form available on the Website, we collect your name, email address, and any information that you decide to include in your message. When you contact us through WhatsApp, we collect your phone number and any information that you provide us with in your messages. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to grow and promote our business). We will store such data until you stop communicating with us (no longer than 1 month).
• Newsletters. When you provide us with your email address for service provision purposes, we may use your email address to deliver our newsletter and inform you about our services, new content, and special offers. The legal basis on which we rely is ‘pursuing our legitimate busines interests’ (i.e., to grow and promote our business). You can opt-out from receiving our newsletter at any time free of charge by clicking on the “unsubscribe” link included in our newsletter or by contacting us directly. We will store your email address until you unsubscribe from our newsletter. 

2.3 Cookies. When you browse the Website, we collect your cookie-related data and use other tracking technologies as described in detail in section 7 “Cookies, Tracking, and Advertising.” 

2.4 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.    

2.5 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to receive the requested information or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.  

2.6 Collection of analytics data. When you browse the Website, we collect certain technical analytics data collected from you. Such data includes the following information: 

• URL addresses from which you access the Website;
• Your device type;
• The operating system of your device;
• Interactions per visit; 
• Exit pages; 
• Bounce rates; 
• Conversion rates; 
• IP address; and 
• Your other online behaviour.

2.7 Purposes of analytics data. We use your analytics data to analyse what kind of users access and use the Website, measure your engagement with the Website, see which parts of the Website are interesting to you, develop new services and features of the Website, and investigate and prevent security issues and abuse. In most cases, such analytics data is non-personal and it does not allow us to identify you as a natural person. However, your IP address may be considered personal data and we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that are personal data, we rely on the ‘legitimate interest’ (i.e., to analyse, improve, and protect the Website) and ‘your consent’ bases (when we ask for cookie consent). 

2.8 Social media icons. When you click on the social media icons available on the Website, your social media network may share certain data about your online behaviour. We use such data to analyse your use of the Website and improve our services. The legal basis on which we rely is ‘pursuing our legitimate interests’ (i.e., to analyse and improve the Website). We will store this data for no longer than 1 year.

2.9 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records). 

2.10 Aggregate and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregate data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.

3. HOW LONG DO WE STORE YOUR DATA?

In this section, we explain for how long we keep your data in our systems and how we delete it.

3.1 Storage of personal data. We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Privacy Notice or until you request us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2.2. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than strictly necessary.

3.2 Storage of non-personal data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Notice. This may include storing non-personal data for the period of time needed for us to examine our activities, fulfil our contractual obligations, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

3.3 Storage as required by law. In very seldom cases, we may be obliged by law to store your personal data for a certain period of time. If such a requirement exists, we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.

4. HOW DO WE DISCLOSE YOUR DATA?

In this section, you can find information about third parties that may have access to your personal data.

4.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:

• Ensuring the proper operation of the Website;
• Responding to your enquiries;
• Pursuing our legitimate interests;
• Enforcing our rights, preventing fraud, and security purposes;
• Carrying out our contractual obligations;
• Law enforcement purposes; or 
• If you provide your prior consent to such a disclosure. 

4.2 List of data processors. We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Privacy Notice and the applicable data protection laws. The data processors that will have access to your personal data are: 

• Our web hosting service provider Bluehost (https://www.bluehost.com) located in the United States;
• Our mailing service provider Google (https://mail.google.com) located in the United States; 
• Our analytics service provider Google Analytics (https://analytics.google.com) located in the United States; and
• Our independent contractors and consultants.

4.3 International transfers. Some of our data processors may be based outside the country where you reside. For example, if you reside in a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved Standard Contractual Clauses).

4.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving the Website, responding to lawful requests from public authorities or developing new products and services. 

4.5 Legal requests. If requested by a public authority, we will disclose information about the users of the Website to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

5. HOW DO WE PROTECT YOUR DATA?

Here you can find information on how we protect your data against breaches.

5.1 Security measures. We implement technical and organisational information security measures   that protect your personal data from loss, misuse, unauthorised access and disclosure. The security measures taken by us include secure servers, proper authentication, secured networks, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), and carefully selected data processors.

5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law. 

6. HOW CAN YOU MANAGE YOUR PERSONAL DATA?

Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights. 

6.1 The list of your rights. You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:

• • Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
  • Right to rectification: you can rectify inaccurate personal data that we hold about you;
  • Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
  • Right to restriction: you can ask us to restrict the processing of your personal data;
  • Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
  • Right to object: you can ask us to stop processing your personal data;
  • Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
  • Right to complaint: you can submit your complaint regarding our processing of your personal data.

6.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of the Privacy Notice and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can find you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

7. COOKIES, TRACKING, AND ADVERTISING

7.1 We use cookies on the Website in order to analyse the technical aspects of your use of the Website, conduct our marketing campaigns, prevent fraud and abuse, and ensure the security of the Website. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., analyse our content and protect the Website) and ‘your consent’. Unless cookies expire earlier, we store this data as long as analytics records are necessary for our activities or you withdraw your consent.

7.2 We may use different types of cookies on the Website, including: 

• Essential technical cookies that are strictly necessary to ensure the correct functioning of the Website and provide the services requested by you; 
• Preference cookies that allow us to save and preserve your preferences; 
• Marketing cookies that allow us to create, implement, and examine our marketing campaigns. Such cookies allow us to reach the right customers, analyse the productivity of our marketing campaigns, and offer you personalised advertisement; and
• Statistics cookies that allow us to generate statistical reports about how you use the Website.

7.3 Cookie consent. When you visit the Website, we will ask you to provide us with your consent to our use of all cookies via a cookie consent banner (for example, if we see that you are based in the EU). If you do not provide your opt-in consent, we will not serve you our non-essential (statistics, marketing, and advertising) cookies. Please note that we may not be able to provide you with the best possible user experience if not all cookies are enabled.

7.4 Disabling cookies. When we ask you to provide your consent to our use of non-essential cookies, you have the freedom not to provide such consent. If you would like to refuse our use of non-essential cookies later, you can do it at any time by declining cookies in your browser or device. For more information, you can consult the cookie management instructions of your browser:

• Apple Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Google Chrome: https://support.google.com/chrome/answer/95647 
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences 
• Opera: https://Sites.opera.com/news/2015/08/how-to-manage-cookies-in-opera/ 
• Microsoft Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy

7.5 Tracking pixels. The newsletters sent by us may contain tracking pixels that allow us to conduct analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We may also use tracking pixels to analyse your online behaviour on our Website or other websites. We use such information to conduct business analytics. Please note that our use of tracking pixels is subject to the cookie consent as explained in sections 7.3 and 7.4. If you do not provide your consent, we will not track you by using pixels. 

7.6 Facebook pixels. We may use Facebook pixels that are code snippets placed on our Website to analyse and optimise the Website. Facebook pixel data is sent to Meta Platforms Inc. based in the United States. On the basis of Facebook pixels, Facebook may identify and target you for advertising purposes and you may be presented with advertising that meets your user profile and interests. Pixels also help us understand the effectiveness of our Facebook ads for statistical and market research purposes. For more information on how Facebook pixels work, please visit https://www.facebook.com/gpa/blog/the-facebook-pixel. We use Facebook pixels only of we have a legitimate basis for doing so, such as your consent. 

7.7 Targeted Advertising. You may encounter targeted interest-based advertising based on your use of the Website and other websites on the Internet. We use Google Ads that deliver such services. Such advertising may also be based on profiling that automatically groups the users of the Website. Where necessary, we will seek your consent (for example, for the use of non-essential advertising cookies). You can control how such advertising is shown to you or opt-out from targeted advertising by consulting the guide powered by the Digital Advertising Alliance available at https://youradchoices.com. For more information on opting-out from advertising features on your device, please visit https://thenai.org. Where interest-based advertising uses non-essential cookies, we will ask your consent for such cookies. Also, you may adjust the settings of your Google account to manage the advertising content that you are served.

7.8 Google Analytics. We use Google Analytics, a web analytics service provided by Google LLC registered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google generates statistical information by means of cookies and creates reports about your use of the Website. The cookies served by Google are anonymous first-party cookies that do not allow us to identify you in any manner. The information generated by cookies will be transmitted to and stored by Google on servers in the United States. To ensure your privacy, your IP address will be anonymised and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For more information about Google Analytics’ privacy practices, please visit https://support.google.com/analytics/answer/6004245. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en. We will ask you to provide us with your consent for non-essential Google Analytics cookies through a cookie consent banner. If you do not provide such consent, we will not use Google Analytics to analyse your use of the Website.

7.9 List of cookies and pixel trackers. Below, you can find a list of cookies and pixel trackers that we use on the Website, including their purpose and expiration time:

8. CONTACT

If you have any questions about this Privacy Notice, your rights, or our data protection practices, please contact us by using the following contact details:

Email: disputes@snfighters.com

Contact form: https://snfighters.com/contact/ 

Postal address: FIGHTERS INTERNATIONAL, Rue Vanderkindere 171/ 14, Brussels 1180, Belgium

[END]