Clubwise privacy policy

This translation is provided for convenience. In case of differences, the Dutch version prevails.

Publication date: 10 June 2026

1. Why this privacy policy?

Crypton attaches great importance to the protection of your privacy and personal data. Crypton uses your personal data solely in accordance with the Privacy Act. Every reference in this Privacy Policy to "Privacy Legislation" refers to Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR"), the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data and other applicable national legislation supplementing or implementing the GDPR.

With this Privacy Policy, Crypton wants to explain in clear and plain language who Crypton is and what you can turn to Crypton for, which personal data Crypton collects from you, for which purposes Crypton processes this personal data, on which legal basis it bases this processing, to whom your personal data may be passed on, how long Crypton keeps your personal data, how Crypton protects your personal data and which rights you have with regard to the processing of your personal data.

From time to time it may be necessary to change this Privacy Policy. When we publish changes to the policy, we change the publication date at the top of the policy. The most recent version of this Privacy Policy is available on our website at all times.

2. Who is Crypton?

Crypton offers a platform https://{clubname}.clubwise.be (hereinafter: the "Platform") and the application https://{clubname}.clubapp.be (hereinafter: the "App"), together with related services (hereinafter: the "Services"), to sports clubs (hereinafter: the "Customer").

In the course of its activity, Crypton collects, uses, stores, shares or otherwise processes personal data.

3. When does this Privacy Policy apply?

This Privacy Policy applies to the situations in which Crypton processes personal data in its capacity as data controller. Crypton acts as data controller, among others:

• When it processes personal data of data subjects who gain access to the Services in the name and on behalf of the Customer (such as employees of the Customer)
• When it collects personal data directly from data subjects in order to provide a Service to the Customer (such as when identifying or authenticating users of the App)
• When a data subject contacts Crypton (for example to ask a question about its services)
• When (the company of) a data subject enters into an agreement with Crypton (for example a supplier agreement)
• When a data subject visits the Crypton website
• When a data subject applies for a job at Crypton.

4. Which personal data does Crypton process?

Crypton undertakes to process only the data that is relevant for the purposes for which it needs it, as set out in article 5 of this Privacy Policy. Whenever certain personal data is mandatory and other data only optional, this will be clearly indicated when the personal data is collected, so that you freely choose which personal data you provide, if any.

The following categories of personal data may be processed by Crypton:

When your company is a Customer of Crypton or you otherwise gain access to the Platform, the App or the Services on behalf of a Customer:

• Identification data
• Financial details
• Personal characteristics
• Leisure activities and interests
• Consumption habits
• Housing characteristics
• Data on education and training
• Data on profession and employment
• Image recordings
• Sound recordings

When you use the App as an end user of the Customer (for example as a club member or supporter):

• Identification and contact data such as name and e-mail address
• Payment data such as bank card number and account number.

When you contact Crypton:

• Identification and contact data such as name, title, e-mail address, phone or mobile number.

When you are (a contact person of) a contracting party of Crypton, such as a supplier:

• Identification and contact data such as name, title, e-mail address, phone or mobile number.

When you visit the Crypton website:

• Electronic identification data: information collected through cookies (read our Cookie statement).

When you apply for a job at Crypton:

• Identification and contact data such as name, title, e-mail address, phone or mobile number, address
• Personal characteristics such as age, gender, place of birth, date of birth
• Data on education and training such as academic curriculum, professional experience, professional competence, curriculum vitae
• Current profession and career
• A picture.

You always provide the personal data to Crypton yourself and can thus exercise a certain degree of control. If certain data is incomplete or apparently incorrect, Crypton reserves the right to postpone certain expected actions temporarily or permanently.

5. For which purposes is your personal data used and on which legal basis does Crypton rely?

Crypton may use the aforementioned personal data for the following purposes:

• To provide Services to its Customers
• For its customer and supplier management
• For the management of (invoicing) disputes and claims
• For the management and optimisation of its website
• To follow up requests and questions and send you the requested information
• To contact potential customers or prospects and for public relations
• With a view to recruitment.

For your complete information, you can find the relevant legal grounds for these processing activities below:

• For the processing of personal data with a view to building a recruitment reserve and for direct marketing, Crypton relies on your consent.
• Crypton bases the processing of personal data for the management of suppliers who are natural persons on the necessity for the performance of the agreement it has concluded with the data subject. If you provide Crypton with no or incorrect personal data, Crypton cannot guarantee that an agreement will be concluded with you or that the agreement will be performed correctly.
• Crypton bases the processing of personal data for the management of its Customers and suppliers that are legal entities, the management of disputes and claims, the management of its website, the handling of questions, contacting potential customers or prospects and the performance of Services for its Customers on the necessity for the purposes of the legitimate interests pursued by it or its Customers (in particular the interest in performing the agreement concluded with the Customer or supplier correctly, safeguarding its rights, the proper functioning of its website and promoting its business in general, both online and offline). Before Crypton processes personal data on this legal basis, Crypton has carried out a balancing of interests and established that the protection of your personal data and your other fundamental rights and freedoms is not infringed to such an extent that it overrides the legitimate interests concerned. In doing so, Crypton takes into account the nature of the interest, its compelling character, the consequences of the processing for you, the amount and nature of the personal data collected, the processing carried out by Crypton and your reasonable expectations.
• The storage of accounting data and the execution of any court orders take place on the basis of a legal obligation.

6. With whom does Crypton share your personal data?

Crypton may pass on your personal data to the following parties:

• Service providers acting as "processors" for Crypton, such as external IT service providers
• Professional advisers such as external law firms or accountants
• Government authorities, only if there is a legal obligation to do so.

Please note: this list is not exhaustive. There may be other cases in which Crypton has to inform other parties in order to provide its services as effectively as possible. Crypton considers this necessary in accordance with its mutual interests.

When transferring data to third parties, Crypton always ensures that it takes appropriate protective measures. Crypton works with service providers who process certain personal data on its behalf. This takes place solely in accordance with the applicable Privacy Legislation. In particular, Crypton has concluded transfer agreements or a data processing agreement with its service providers, insofar as required by law, which meet the requirements of article 28 of the GDPR, and it instructs the service providers on how to handle the personal data. Through careful selection and regular checks, Crypton ensures that its service providers take all organisational and technical measures necessary to protect your personal data.

Your personal data will not be lent or sold to third parties for marketing purposes without your prior explicit consent.

Your personal data will not be transferred to recipients in countries outside the European Economic Area.

7. Crypton also uses cookies

During a visit to the Platform, the App or the Crypton website, "cookies" may be placed on your hard drive in order to better tailor the Platform, the App and the website to the needs of the returning visitor. Non-functional cookies help us optimise your visit to the Platform, the App or the website and keep track of technical choices.

For a further understanding of how Crypton uses cookies to collect and process your personal data, Crypton kindly refers you to its Cookie statement.

For an optimal user experience, it is recommended that you have cookies enabled. How you can disable cookies is also described in the Cookie Statement.

8. How long does Crypton keep your personal data?

Crypton does not keep your personal data longer than necessary for the purposes for which it is collected and processed (as described above).

• Personal data included in accounting, financial or other official documents will be kept for as long as these documents must be kept by law; for accounting records this is at least 10 years
• Personal data required for the performance and follow-up of a contractual relationship will be kept for the entire duration of that relationship and for 10 years after its termination
• Personal data collected in the context of providing the Services to the Customer via the App will be deleted as soon as you have not accessed the App for an uninterrupted period of 2 years
• Personal data collected in the context of customer acquisition will be kept until 2 years after collection or the last contact from the potential customer, if they have not become a customer
• Personal data collected in the context of an application procedure will, subject to the consent of the data subject, be kept until 2 years after collection in order to build a recruitment reserve
• As regards the personal data of website visitors, Crypton refers to the Cookie statement.

Only when Crypton is legally obliged to do so, or if it is necessary to defend its interests in court (for example in the event of a dispute), will Crypton keep your personal data for a longer period. More information about the retention periods is available on simple request.

9. How does Crypton protect your personal data?

Crypton takes appropriate technical and organisational measures to ensure a level of security appropriate to the specific risks it has identified. In this way, Crypton protects your personal data as well as possible against destruction, loss, alteration, or unauthorised disclosure of or access to transmitted, stored or otherwise processed personal data.

If Crypton works with a third party, the necessary contractual arrangements have been made to process your personal data securely. More information about our security measures is available on simple request.

10. What are your rights?

Exercising the rights below is in principle free of charge. Only in the case of unreasonable or repeated requests may Crypton charge a reasonable administrative fee.

Crypton always tries to respond to your requests or questions as quickly as possible. Crypton may first ask you for proof of identity in order to verify your identity.

For further information and advice on the rights below, Crypton refers you to the website of the Data Protection Authority: www.gegevensbeschermingsautoriteit.be.

You can exercise the rights below by sending an e-mail to info@crypton.be.

Right of access

Upon proof of your identity, you have the right to obtain confirmation from Crypton as to whether or not your personal data is being processed. When Crypton processes your data, you also have the right to access the personal data collected and to receive information about how and why Crypton processes your personal data. You can also receive a copy of the personal data.

Right to rectification

Inaccurate or incomplete personal data can always be rectified. It is primarily up to you to correct inaccuracies and incomplete data yourself. You can exercise your right to rectification by providing a supplementary statement to Crypton.

Right to erasure (right to be forgotten)

You also have the right to have your personal data erased by Crypton without undue delay. You can only invoke this right to be forgotten in the following cases:

• When the personal data is no longer necessary for the purposes for which it was originally collected
• When the personal data was collected on the basis of consent and there is no other legal ground for the processing
• When an objection is made to the processing and there are no overriding compelling legitimate grounds for the processing
• When the personal data has been processed unlawfully
• When the personal data must be erased in accordance with a legal obligation
• When the personal data is processed on the basis of consent given by a minor.

Crypton assesses whether one of the aforementioned cases applies.

Right to restriction of your personal data

You have the right to obtain restriction of the processing of your personal data:

• During the period Crypton needs to verify the accuracy of the personal data, after you have contested its accuracy
• When the data processing is unlawful and you request restriction of the processing instead of erasure of the personal data
• When Crypton no longer needs your personal data for the processing purposes and you need the personal data for a legal claim
• During the period Crypton needs to assess whether the grounds for erasing personal data apply.

Right to object

You also have the right to object to the processing of your personal data at any time. Crypton will then stop processing your personal data, unless Crypton can demonstrate compelling legitimate grounds for the processing of your personal data that override your right to object.

Right to data portability

You have the right to obtain the personal data you have provided to Crypton in a structured, commonly used and machine-readable format. In addition, you have the right to transfer this personal data to another controller when the processing of the personal data is based solely on your consent.

Right to withdraw your consent

You have the right to withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint

In addition to the aforementioned rights, you always have the right to lodge a complaint with the competent supervisory authority regarding our processing of your personal data. In Belgium this is the Data Protection Authority (GBA/APD). You can reach the authority via contact@apd-gba.be or by post at the following address: