Privacy Policy

Last updated: February 2026

Preamble

Sclubber LLC (hereinafter – Sclubber, we, us, our) prioritizes the security and confidentiality of personal data. We operate a technology platform that enables Users to discover, book, and pay (where available) for sports and fitness activities offered by independent third-party Clubs. We are committed to processing personal data lawfully, fairly, and transparently, applying appropriate technical and organisational safeguards, and limiting processing to what is necessary for legitimate, clearly defined purposes.

This Privacy Policy should be read together with the Sclubber Terms and Conditions (for Users and for Clubs) and any additional privacy notices displayed at the time of data collection.

1. Policy Objective and Scope

This Privacy Policy describes how Sclubber collects, uses, discloses, stores, and protects personal data when you access or use the Platform, including through the Sclubber mobile application, website, and Club portal.

This Privacy Policy applies to:

• natural persons who register, browse, book, attend, review, or otherwise use the Platform as Users;
• representatives, staff, or trainers of Clubs, insofar as Sclubber processes their personal data in connection with Club registration and Activity management; and
• any individual who communicates with Sclubber or submits a request, complaint, or dispute through the Platform.

This Privacy Policy does not apply to third-party websites, applications, or services that may be linked from the Platform. Clubs are independent service providers and may process personal data under their own privacy practices; however, Clubs that receive User personal data through the Platform are contractually obliged to protect it as described in Section 9 of this Policy and the Club Terms.

By registering for and using the Platform, you acknowledge that your personal data will be processed as described in this Privacy Policy.

2. Who We Are and How to Contact Us

Sclubber LLC is the data processor for personal data processed through the Platform for the purposes described in this Privacy Policy.

Contact details:

• Legal name: Sclubber LLC
• Identification Number: 405823514
• Legal address: Georgia, Tbilisi, Vake district, Zakaria Paliashvili st. N 64 b. 20
• Email: [email protected]
• Website: sclubber.com

3. Purposes of Personal Data Processing

Sclubber processes personal data to operate and administer the Platform and related services, including for the following purposes:

• registering Users and Clubs, creating and managing accounts, and authenticating access;
• enabling Activity discovery, booking requests, booking confirmations, attendance management, and booking history;
• facilitating communications between Users and Clubs in connection with bookings;
• enabling online payments where selected, supporting refunds, cancellation workflows, and dispute handling under the applicable policies;
• maintaining and improving Platform functionality, performance, and user experience, including analytics and diagnostics;
• displaying and administering ratings, rankings, reviews, and feedback mechanisms, and moderating content;
• providing informational features such as weather suitability indicators for outdoor Activities and notifications relating to potential cancellations or changes;
• preventing fraud, abuse, unauthorised access, chargeback abuse, manipulation of reviews, and other violations of Platform rules;
• complying with legal obligations, responding to lawful requests, and establishing, exercising, or defending legal claims;
• sending service communications (booking confirmations, reminders, policy updates, security alerts); and
• sending marketing communications where legally permitted and/or where consent is obtained, and managing marketing preferences.

Sclubber does not process personal data for purposes incompatible with those described above unless permitted by law and, where required, upon appropriate notice and/or consent.

4. Legal Basis and Form of Personal Data Processing

Sclubber processes personal data only where an applicable legal basis exists, including:

• performance of a contract with you or taking steps at your request before concluding a contract (e.g., account creation, bookings, communications);
• compliance with legal obligations (e.g., financial, accounting, consumer protection, lawful requests);
• legitimate interests pursued by Sclubber or a third party (e.g., platform security, fraud prevention, service improvement, enforcing Terms);
• consent, where required (e.g., marketing, precise location data, optional sharing of contact details with Clubs); and
• protection of vital interests in exceptional circumstances (e.g., emergencies involving safety).

Processing is carried out by automated, semi-automated, and non-automated means depending on the nature of the processing activity.

5. Categories of Personal Data and Sources of Collection

Personal data collected directly from Users may include:

• identification and contact data (name, email, phone number, profile photo);
• account credentials (password in encrypted/hashed form, authentication tokens);
• profile information (sports interests, fitness level preferences, settings);
• booking and attendance data (selected Activities, dates, times, locations, participation status);
• communications (messages and support requests submitted through the Platform);
• user-generated content (ratings, reviews, uploaded photos, complaints); and
• optional data provided by the User (e.g., optional contact fields, preferences).

Personal data collected automatically may include:

• device and technical data (device type, OS, identifiers, app version, network information);
• usage and interaction data (pages viewed, features used, clicks, session duration);
• log data (IP address, access times, referrer URLs);
• approximate location inferred from IP, and precise location where enabled and consented via device settings; and
• diagnostic data (crash reports and performance logs).

Personal data obtained from third parties may include:

• social login data (limited profile information you authorise the provider to share);
• payment service provider confirmations (payment status, transaction reference, fraud signals—without storing full card data where processed by the provider);
• analytics providers (aggregated usage patterns); and
• publicly available sources where lawful and necessary (e.g., for business verification of Clubs).

Sclubber does not intentionally collect special category data (such as health data) as a requirement for Platform use. If any such data is voluntarily included in user content or support requests, it will be processed only to the extent necessary to address the request and protect Platform integrity.

6. Cookies, SDKs, and Tracking Technologies

The Platform may use cookies, SDKs, pixels, and similar technologies to enable core functionality, analytics, and where permitted marketing. You can find our Cookie Policy available at: https://sclubber.com/cookies.html.

The types of technologies may include:

• strictly necessary technologies for authentication, security, and session management;
• analytics technologies to understand usage and improve services;
• preference technologies to remember settings; and
• marketing technologies, where consent is required and obtained.

Sclubber may use third-party analytics and crash reporting tools (for example, Google Analytics, Firebase Analytics, Crashlytics or similar), subject to configuration and legal requirements.

You may control cookies via browser settings and, where available, through in-app privacy controls. Device-level settings may also allow restrictions on tracking and location access.

7. Disclosure and Sharing of Personal Data

Sharing with Clubs

When you book an Activity, Sclubber may share with the relevant Club the personal data reasonably necessary to organise and deliver the Activity, which may include:

• name;
• profile photo (if uploaded);
• booking details (Activity, time, place, attendance status); and
• your phone number and/or email address only where enabled by you or otherwise required for fulfilment.

Sclubber does not authorise Clubs to use this data for unrelated purposes.

Sharing with Service Providers

Sclubber may share personal data with trusted external service providers supporting Platform operation, such as:

• cloud hosting and infrastructure providers;
• payment service providers;
• messaging providers (email/SMS/push notifications);
• analytics and performance providers;
• customer support tools;
• fraud prevention and security providers;
• professional advisers (legal, accounting, audit) where necessary.

Such providers are required by contract to protect personal data and process it only in accordance with Sclubber's instructions and lawful purposes.

Legal Disclosures

Sclubber may disclose personal data where necessary to comply with legal obligations, respond to lawful requests from competent authorities, enforce the Terms, or protect rights, safety, or property.

If Sclubber participates in a merger, acquisition, restructuring, or asset sale, personal data may be transferred as part of that transaction, subject to lawful safeguards and notice where required.

Sclubber may share personal data with additional recipients where you provide clear consent or direct instruction.

8. International Transfers

Sclubber may store or process personal data in jurisdictions outside your country of residence, including where service providers operate global infrastructure.

Where required, Sclubber implements appropriate safeguards for cross-border transfers, which may include standard contractual clauses and other lawful mechanisms.

9. Club Privacy Obligations (User Data Confidentiality)

Where a Club receives User personal data through the Platform, the Club undertakes to:

• use such data solely for organising, delivering, and administering the booked Activity and related communications;
• restrict access to authorised staff only on a need-to-know basis;
• maintain appropriate technical and organisational security measures;
• refrain from using User personal data for marketing, profiling, or unrelated contact unless the User has provided separate, explicit consent directly to the Club or such processing is otherwise lawful;
• refrain from selling, disclosing, transferring, or otherwise exploiting User personal data;
• promptly notify Sclubber of any actual or suspected personal data breach affecting User data obtained through the Platform; and
• comply with applicable data protection law and the Club Terms.

The Club bears full responsibility and liability for its own processing of User personal data and shall indemnify Sclubber for losses arising from the Club's unlawful or unauthorised processing.

10. Personal Data Retention

Sclubber retains personal data only for 5 (five) years from retention for the purposes described in this Policy, including contractual performance and legal obligations.

Upon account deletion, Sclubber will delete or anonymise personal data within 10 (ten) days, except where retention is required by law or necessary for the establishment, exercise, or defence of legal claims.

11. Your Rights and How to Exercise Them

Your rights to Data Processing are following:

• the right to access and obtain a copy of personal data;
• the right to correct or update inaccurate data;
• the right to request deletion, where legally permitted;
• the right to restrict or object to certain processing;
• the right to data portability where applicable;
• the right to withdraw consent at any time where processing is based on consent; and
• the right not to be subject solely to automated decision-making that produces legal or similarly significant effects, where applicable.

Requests may be submitted through:

• the Platform: Settings → Privacy → Data requests; or
• by email to: [email protected]

Sclubber may request identity verification to protect your data and prevent unauthorised disclosure.

Sclubber will respond within 10 (ten) business days.

12. Security of Personal Data

Sclubber implements appropriate technical and organisational measures, which may include encryption in transit, access controls, authentication safeguards, monitoring, incident response procedures, and staff confidentiality obligations.

No system is fully secure. You are responsible for safeguarding your account credentials and promptly notifying Sclubber of suspected unauthorised access.

13. Children and Minors

Users must be at least 16 years old to create an account. Users aged 16–17 may be required to obtain parental or guardian consent as determined by the Platform rules.

Users under 16 may not create accounts. Where Sclubber becomes aware of an underage account, it may delete the account and associated data, subject to legal requirements.

14. Biometric Data

Sclubber does not intentionally collect biometric identifiers (such as fingerprint templates or facial recognition profiles). If this changes, Sclubber will provide appropriate notice and obtain required consents.

15. Third-Party Links

The Platform may contain links to third-party services. Sclubber is not responsible for third-party privacy practices and recommends reviewing third-party policies before use.

16. Marketing Communications

Sclubber may send marketing communications only where you have provided consent.

You may opt out at any time through in-app settings or by following the unsubscribe mechanism in communications.

17. Complaints and Supervisory Authority

If you believe your data protection rights have been violated, you may contact Sclubber using the channels in Section 2.

You may also have the right to contact the competent supervisory authority under applicable law. Where relevant, the personal data protection authority contact information may be found at https://pdps.ge/en.

18. Changes to This Privacy Policy

Sclubber may amend this Privacy Policy from time to time. Updates will be posted on the Platform, and where required, Users will be notified via in-app notice, email, or other lawful channels.

Continued use of the Platform after the effective date of an updated Privacy Policy constitutes acceptance, to the extent permitted by law.

By using Sclubber, you acknowledge that you have read and understood this Privacy Policy.