FRESH APPLES CREW

PRIVACY

Who controls your data

The controller is MTÜ BREAKING EESTI, registration number 80655643, Estonia. Contact: freshapplescrew@proton.me. Updated 20 September 2026.

Enquiries and enrolment

The contact form prepares an email in your email app. Your name, email, city, topic and message remain in page memory until you choose to send the email. The website does not store drafts or automatically transmit them. The club receives sent messages through Proton Mail and uses them to reply and discuss enrolment. A parent or legal guardian must enquire on behalf of a child. Do not include health information or a child’s personal identification code.

Legal basis and retention

Enrolment enquiries are processed to take steps at your request before entering a contract (GDPR Article 6(1)(b)). General enquiries rely on the club’s legitimate interest in responding (Article 6(1)(f)). The club deletes enquiries that do not result in enrolment within six months after the discussion ends, unless needed to resolve a dispute. Separate retention terms apply to enrolled members.

Photos

The club must hold publication rights and an applicable legal basis for photos of coaches, athletes and events. Identifiable children’s photos require permission from their legal representatives, with evidence held separately by the club. Photo consent is not a condition of attending training. Where publication is based on consent, you may withdraw it by emailing the club; this does not affect prior lawful processing. Images remain until permission is withdrawn or the publication purpose ends, with an annual review. A deleted image may remain in the site cache for up to five minutes. Copies saved by others are outside the club’s control.

Hosting and recipients

This site uses Cloudflare Pages; uploaded images are stored in Cloudflare R2. These providers process technical connection data, including IP addresses and browser information, to deliver and protect the site. Administrator sign-in is protected by Cloudflare Access and restricted to approved email addresses. Proton Mail handles correspondence. Following Instagram links opens a service subject to Meta’s terms. Providers may process data outside the EEA. Before a public launch, the club must confirm processor agreements, international transfer safeguards and technical log retention with the selected providers.

Cookies

Our site code contains no advertising cookies or analytics. Fonts are hosted locally and neither Instagram nor maps are embedded. The necessary-only preference is saved in localStorage as fac-privacy and can be removed through browser settings. Cloudflare Access may use necessary cookies for administrator authentication and security. No optional trackers are loaded, so consent for them is not requested.

Your rights

You may request access, rectification, erasure, restriction and, where applicable, portability; object to processing based on legitimate interests and withdraw consent. Email the club. We normally respond within one month; complex requests may require an extension with notice. You may complain to Estonia’s Andmekaitse Inspektsioon. The site does not use automated decision-making or profiling.

Before public launch

The club must approve this policy and confirm provider terms and publication permissions before making the site publicly accessible.