Privacy Policy

Effective date: 25 August 2025
Applies to: Spartan Martial Arts And Fitness LLC (the “Gym”, “we”, “us”, or “our”), operating in Sharjah, United Arab Emirates.

This Privacy Policy explains how we collect, use, disclose, transfer, and safeguard Personal Data in our physical locations, websites, mobile applications, and any other services we provide (collectively, the “Services”). It is designed to align with the UAE Federal Decree‑Law No. 45 of 2021 Regarding the Protection of Personal Data (“PDPL”) and related UAE laws.

1) Who we are & how to contact us

Controller: Spartan Martial Arts And Fitness LLC
Registered address: Spartan Martial Arts And Fitness, Maleha St - Warehouses Lands - Sharjah
Trade/License No.: 771443
Privacy contact: info@spartans.ae | +971 50 5880685
Data Protection Officer (if appointed): Not Appointed
Complaints: You may contact us first. You also retain the right to complain to the UAE Data Office or competent authority under the PDPL.

2) Key terms

• Personal Data means any information relating to an identifiable natural person.
• Sensitive Personal Data includes health and fitness information, biometric data, and any data revealing ethnicity, beliefs, or criminal record.
• Processing means any operation performed on Personal Data (collection, storage, use, disclosure, transfer, deletion, etc.).

3) The data we collect

• Identity & contact data: name, date of birth, nationality, Emirates ID/passport details, photo, contact information.
• Membership & transactional data: membership tier, dates, attendance history, class bookings, payment records, invoices, loyalty points, referral codes.
• Health & fitness data: medical declarations, PAR‑Q responses, body measurements, training goals, trainer observations.
• Access & security data: entry logs, key‑card/RFID data, incident reports.
• CCTV footage in public areas (not in changing rooms, showers, or toilets).
• Digital data: device identifiers, IP address, cookies, browsing and app usage data.
• Marketing preferences: consents for email, SMS, WhatsApp, phone; event/photo consent choices.
• Third‑party data: from payment providers, partners, or insurance/wellness programs.

4) Why we process your data & legal bases

Special rules apply for Sensitive Personal Data; we obtain your explicit consent unless another PDPL condition applies.

5) CCTV notice

We operate CCTV in entrances, reception, corridors, gym floors, and studios, but never in changing rooms, showers, or toilets. Retention is 90 days unless an incident requires longer. Access is limited to trained staff and authorized vendors. Clear signage is displayed in monitored areas.

6) Children & teens

Services are for members aged 13+. For members under 18, a parent/guardian must sign contracts and provide consent for health data and images.

7) Marketing & your choices

We send marketing by email, SMS, WhatsApp, or phone only with your consent or where permitted by law. You can opt out anytime. We honor the UAE Do‑Not‑Call registry and do not sell your data.

8) Disclosures to third parties

We may share Personal Data with processors (IT, payments, messaging providers), professional advisors, public authorities, and program partners. Vendors cannot use your data for their own marketing without your consent.

9) International transfers

If Personal Data is transferred outside the UAE, we ensure PDPL‑compliant mechanisms apply, such as adequate jurisdictions, explicit consent, or contract necessity, with safeguards in place.

10) Your rights

• Access and copy your data.
• Request correction or erasure.
• Restrict or object to processing, including marketing.
• Data portability.
• Not be subject to automated decisions with legal effects, unless permitted by law with safeguards.

To exercise rights, contact info@spartans.ae. We will respond without undue delay.

11) Data retention

• Membership/account data: 1 month after account closure unless legally required longer.
• Health/assessment records: retained for audience understanding and feedback, and up to 3 years after last interaction.
• CCTV: 90 days unless needed longer for investigation.

We anonymize or securely delete data when retention ends.

12) Security

We implement appropriate technical and organizational measures, including access controls, encryption, training, vendor checks, and incident response. Sensitive Personal Data access is strictly limited.

13) Data breaches

If a breach poses risk to your rights, we will notify the competent UAE authority and affected individuals without undue delay, documenting all incidents.

14) Photos, filming & member etiquette

Members may not photograph/film others without consent. We may hold events or shoots and will notify you in advance. Promotional images may be taken; you can opt out anytime.

15) Third‑party links

Our site/app may link to third‑party platforms. Their privacy practices are governed by their own policies.

16) Changes to this Policy

We may update this Policy. The latest version will have a new effective date. We will notify you of material changes.

17) Local addenda

Sharjah addendum: CCTV signage is displayed; no cameras are in changing rooms, showers, or toilets. CCTV is used only for safety/security and managed by trained staff.
Arabic version: An Arabic version will be made available. If discrepancies arise, the Arabic version prevails.

18) Contact

Privacy Team
Spartan Martial Arts And Fitness LLC
info@spartans.ae | +971 50 5880685 | Spartan Martial Arts And Fitness, Maleha St - Warehouses Lands - Sharjah