ROW'S PRIVACY POLICY
1. Policy Summary and Treatment OverviewDATA CONTROLLER
EKV BV
D'Haenestraat(HEU) 34, 9070 Destelbergen
Belgian Trade and Companies Register n°1008.800.493
hello@rowreformer.comRECIPIENTS OF THE PERSONAL DATATrainin, our online booking tool,Bsport, our former online booking tool — personal data will be retained in Bsport until 31 August 2026 as part of our migration to Trainin,Webflow, our website building and hosting tool,Mollie, our online payment tool (via Trainin),Stripe, our former online payment tool (via Bsport) — personal data will be retained until 31 August 2026 as part of our migration to Trainin,Instagram and Facebook, social media platforms we use to build and gather our community.DATA SUBJECT'S RIGHTSRight to access your data;Right to rectify, update and complete data;Right to erase your data;Right to a limitation of the processing;Right to the portability of your data;Right to object to the processing;Right to withdraw your consent.AUTOMATED DECISION-MAKING
Not applicableTRANSFER OF PERSONAL DATA TO A THIRD COUNTRY
Yes, USA, where Webflow and Instagram & Facebook are based, and where Stripe (legacy, until 31 August 2026) is based. Trainin (Latvia), Mollie (Netherlands) and Bsport (France) are based within the European Economic Area.
2. General Provisions
The following Privacy Policy governs the processing of personal data by EKV BV, a company incorporated and existing under the laws of Belgium, with registered offices at D'Haenestraat(HEU) 34, 9070 Destelbergen, listed in the Belgian Trade and Companies Register under n°1008.800.493, (hereinafter "ROW" or "we" or "us").ROW is committed to protecting and respecting your privacy.The purpose of this Privacy Policy is to specify which categories of personal data ROW collects through its business activities, its website www.rowreformer.com, applications, services and any other means relating to information or communication, including emails (hereinafter collectively referred to as the "Services"). It also describes how such data may be processed and disclosed to others. The Privacy Policy further sets out the different measures ROW has implemented to safeguard the security and confidentiality of the personal data it collects, how you can exercise your rights and how you can contact us about our privacy practices.ROW cares about the privacy of the users of its Services and all others whose personal data may be collected (hereinafter "User" or "you" or "your") and will only collect and process personal data in accordance with the provisions of this Privacy Policy.ROW is the Data Controller. ROW will act in compliance with the General Data Protection Regulation (EU Regulation 2016/679 of 27 April 2016) and all other applicable data protection legislation such as the Belgian Act of 30 July 2018 regarding the protection of natural persons in relation to the processing of personal data, and as further detailed in the present Privacy Policy ("Applicable Data Protection Laws").Should you have any questions about this Privacy Policy or the feeling that your interests are not or inadequately represented, you can contact us via email hello@rowreformer.com) or by sending a letter to the above-mentioned address.According to the Applicable Data Protection Laws, you may be entitled to file a complaint with your local Supervisory Authority or the lead Supervisory Authority, such as the Belgian Data Protection Authority (address: Rue de la Presse 35, 1000 Bruxelles, email: contact@apd-gba.be). This will generally be the case when you are located within the European Economic Area (hereinafter the "EEA"), which includes Belgium. We would appreciate it however that, prior to filing any complaint, you contact us for us to assist you with your request or concern.ROW may change this Privacy Policy from time to time. But when we do, we'll let you know one way or another. For example, we may provide you with additional notice (such as adding a statement to our website's homepage or sending you an email). These means of notification will depend on the extent of the modification (substantial change vs minor tweaks). Modified versions will have immediate effect, unless stated otherwise.Please note that the Services may contain links to other websites, digital platforms or Internet resources which may collect personal data voluntarily or through cookies or other technologies. ROW has no responsibility, liability for, or control over those other websites or Internet resources or their collection, use and disclosure of your personal data. ROW recommends that you review the privacy policies of those other websites, tools and Internet resources to understand how they collect and use personal data.
3. CookiesCookies are small text files that are placed on your computer, tablet or mobile phone when you visit our website. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the website.The list below sets out the categories of cookies used on the Website. ROW's Website is built on Webflow, which by default only places cookies that are strictly necessary for the site to function; no separate consent is required for these.ROW does not currently use any analytics or marketing cookies on the Website. If this changes — for example if ROW starts using tools such as Google Analytics or Meta (Facebook/Instagram) Pixel — this Privacy Policy will be updated accordingly, and, where required, your consent will be requested through the cookie banner before such cookies are placed.Strictly necessary cookies
Purpose: enable core website functionality, such as page navigation, form submissions, and remembering your cookie preferences.
Provider: Webflow (ROW's website host).
Duration: session, or up to 12 months for the cookie-preference cookie.Analytics cookies
Not currently used. ROW does not currently place analytics cookies on the Website.Marketing cookies
Not currently used. ROW does not currently place marketing or advertising cookies on the Website.When you first visit the Website, a cookie banner allows you to accept or manage cookies. You can change your preferences at any time by revisiting the cookie settings available on the Website.You can also control cookies through your browser settings. Most browsers allow you to see what cookies are stored on your device and to delete them individually, block cookies from particular or all websites, or block all cookies. Please note that if you choose to block strictly necessary cookies, some parts of the Website may not function properly. For more information, please refer to your browser's help pages (for example Chrome, Safari, Firefox, or Edge).
4. Data Processed by ROW
The categories of personal data which can be processed by ROW depend on the relationship you have with ROW:
4.1. If you are a client of ROWIn a nutshell: you created an account on our website, our application or registered as a client at the studio front desk.Personal data processed: first name, last name, gender, birth date, email address, phone number, information relating to the payment process, address.In B2B relationships, additional information may be requested to provide the client with invoices (VAT number, registered spot, …).When the client registers for classes or workshops but does not attend one or several classes or workshops for which he/she had registered, "no show rates" are generated by ROW.Purpose of the processing: provision of the services (registration for the classes and workshops) and communication with you (this includes sporadic emails with news relating to ROW, new classes and workshops, information on how to register for the new clients, …).Legal basis for the processing: processing is necessary for the performance of a contract to which the data subject is party.
4.2. If you contact ROWIn a nutshell: you are filling out the contact form available on our website in order to receive additional information;Personal data processed: first name, last name, e-mail address, and any relevant personal data you provided ROW with in this context.Purpose of the processing: reaching out to you with the requested information and/or answering your questions.Legal basis for the processing: we rely on our legitimate interest.While we make every effort to ensure that your personal data is accurate, complete and up to date, you can help us considerably in this by promptly notifying us if there are any changes to your data by contacting us as indicated under section 1.Users can't disclose personal data to ROW about another person unless this person has given consent (except when it comes to minimal personal data needed to provide a third party with a gift voucher).ROW will not collect any sensitive data. This includes data such as: data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation from Users. ROW will, if necessary, obtain your explicit consent to collect such data.The User undertakes to communicate correct personal data to ROW. The User can change provided personal data at any time. ROW cannot be held liable for any malfunctioning in the Services due to erroneous personal data communicated by the User or modifications to the User's personal data by third-party management tools.ROW ensures that its direct marketing activities comply with the applicable legislation. ROW does not sell or rent personal data to marketing agencies or third parties.
5. Your rights
Under Applicable Data Protection Law, you may have certain rights regarding the personal data we process about you.You can choose not to provide personal data to us. You also may refrain from submitting data directly to us. However, if you do not provide your personal data when requested, or if you exercise your rights, you may not be able to benefit from the Services (as applicable), and we may not be able to provide you with information about Services.You have the right to:obtain access to the personal data held about you;ask for incorrect, inaccurate or incomplete personal data to be corrected;request that personal data be erased, for example when it's no longer needed;object to the processing of your personal data in specific cases;request the restriction of the processing of your personal data in specific cases;receive your personal data in a machine-readable format and send it to another controller ('data portability');withdraw consent at any time, if the processing is based on consent.If you have any questions on these rights, or if you wish to exercise these rights, please contact us at the following address hello@rowreformer.com.We will then provide information to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.These rights will be exercised free of charge unless the requests are manifestly unfounded or excessive. In the latter cases, ROW can either charge a reasonable fee or refuse the requested action.
6. Disclosure of personal data
Although ROW may transfer personal data to so-called business partners, consultants or other service providers for the performance of the Services (as applicable) or any other contract we enter into with them or you, we will not share data with third parties for secondary or unrelated purposes unless otherwise stated when collecting these data.Recipients ROW may share collected personal data with:Trainin, our online booking software,Bsport, our former online booking software — data retained until 31 August 2026 as part of the migration to Trainin,Webflow, software as a service for our website building and hosting,Mollie, our online payment tool (via Trainin),Stripe, our former online payment tool (via Bsport) — data retained until 31 August 2026,Instagram and Facebook, social media platforms we use to build and gather our community.If ROW gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.Where appropriate or required, ROW will be entitled to transmit personal data to law enforcement authorities, regulatory or other government agencies, or third parties where necessary or desirable to comply with legal or regulatory obligations or in the context of the above-mentioned purposes.As the case may be, one or more of the above may be located outside of the EEA. Where applicable, your personal information will be processed in compliance with section 8.
7. Retention period
ROW does not store the data longer than legally admissible and in any case not longer than required for the purposes for which it was collected unless otherwise required or authorized by Applicable Data Protection Law. We take measures to delete or permanently de-identify your personal data if required by law or if your personal data is no longer required for the purpose for which we collected it.The retention period is the following:All personal data we collect in the framework of our contractual relationship with you as a client, are stored as long as you are a client, and will be deleted 7 years after your last use of our service (last registration for a class/workshop),If you create an online account but do not register for a class/workshop, all personal data will be deleted 2 years after your last connection to our website/app,If you contacted us using the contact form, your data will be deleted 12 months after our latest communication with you,Personal data still held in Bsport (including related payment data processed via Stripe) as part of our migration to Trainin will be retained until 31 August 2026, to ensure continuity of service during the transition, after which it will be deleted or archived in accordance with the retention periods set out above.
8. International data transfers
To offer and perform our Services, ROW may potentially need to transfer your personal data among several countries. The personal data that we collect from you is in principle not transferred to, and stored at, a destination outside the EEA, except when it comes to Webflow, our website building and hosting software, and Instagram & Facebook, the social media platforms we use, which are based in the United States of America (USA). This also applies, on a transitional basis, to Stripe, the payment tool linked to our legacy booking system Bsport, for as long as related data is retained (see section 7).Trainin (based in Latvia), Mollie (based in the Netherlands) and Bsport (based in France) are established within the EEA.We took all steps reasonably necessary to ensure that your personal data is processed and treated securely and in accordance with this Privacy Policy and with the Applicable Data Protection Law. Where personal data is transferred outside the EEA, this is done on the basis of an appropriate safeguard recognised under Applicable Data Protection Law, such as the European Commission's Standard Contractual Clauses or, where applicable, the EU-U.S. Data Privacy Framework.More information can be accessed here:
Trainin: https://trainin.me/privacy_policy
Bsport: https://pro.bsport.io/privacy
Webflow: https://webflow.com/legal/privacy
Mollie: https://www.mollie.com/en/privacy
Stripe: https://stripe.com/privacy
Meta (Instagram & Facebook): https://www.facebook.com/privacy/policy/
9. Security of data
The security of personal data is important to us. ROW shall take all reasonable and appropriate technical and organizational measures to protect the security, confidentiality and integrity of personal data. In particular, ROW will take appropriate measures to prevent any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or other digital assets, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.Unfortunately, the transmission of information via the internet is not without any risks. The User consequently acknowledges that we cannot guarantee the security of her/his personal data to our website or other digital assets (such as our applications, tools, …); any transmission is at your own risk. We will however do our best to protect your personal data once we have received it and will use strict procedures and security features to try to prevent unauthorized access.
10. Collection and Use of Phone Numbers
As part of the registration process, we collect your phone number to facilitate essential communications regarding your use of our services. This includes notifying you of last-minute changes to classes you are registered for or updates that may impact your experience at our studio (e.g., rescheduled classes or temporary disruptions to amenities). Your phone number will be used exclusively for these purposes and will not be shared with third parties or used for any other purposes without your explicit consent.
