Privacy Policy

Champion Spirit International Ltd. (hereinafter "Champion Spirit", "we", "us") attaches the utmost importance to the protection of your privacy. This Privacy Policy describes the personal data we collect via the Champion Spirit mobile application (the "Application"), the purposes of its processing, its retention periods, and your rights.

It is established in accordance with Regulation (EU) 2016/679 ("GDPR") and the French Data Protection Act of January 6, 1978, as amended, applicable to users located within the European Union.

Privacy Policy

Champion Spirit Application, June 17, 2026 Edition

Champion Spirit International Ltd. (hereinafter "Champion Spirit", "we", "us") attaches the utmost importance to the protection of your privacy. This Privacy Policy describes the personal data we collect via the Champion Spirit mobile application (the "Application"), the purposes of its processing, its retention periods, and your rights.

It is established in accordance with Regulation (EU) 2016/679 ("GDPR") and the French Data Protection Act of January 6, 1978, as amended, applicable to users located within the European Union.

1. Data Controller

The data controller for the information collected via the Application is:

  • Publisher (company): CHAMPION SPIRIT INTERNATIONAL LTD, a company incorporated under the laws of the Bahamas (International Business Companies Act, 2000), share capital of 10,000 USD, company registration number 210972 B, with its registered office located c/o Twenty Twenty & Associates, Jander Commercial Centre, Unit No. 4, Second Floor, East Shirley Street, P.O. Box N-7609, Nassau, N.P., Bahamas.

  • Establishment in France (operational publisher): Champion Spirit International Ltd, an establishment located at 9 rue des Filles Saint-Thomas, 75002 Paris, registered with the Paris Trade and Companies Register (RCS) under number 927 786 962 (management number 2024B15744); intra-Community VAT number FR24927786962.

  • Application: Champion Spirit (iOS and Android)

  • Contact: contact@championspirit.com

2. Personal Data We Collect

2.1 Data Provided by You
  • Identification and account data: last name, first name, email address, telephone number, password (encrypted), and profile picture where applicable.

  • QR code identification data: data required for your identification and access to partner services or venues upon presentation of your QR code.

  • Booking data: reserved sports or spa sessions, chosen coach or provider, discipline or service, date, time, and location.

  • Communications: messages addressed to support, reviews, and comments.

2.2 Automatically Collected Data
  • Technical data: device type, operating system, device identifiers, IP address, connection logs.

  • Usage data: features accessed and interactions within the Application.

  • Geolocation data: subject to your consent, your location to recommend nearby coaches, services, and venues. You may disable geolocation at any time within your device settings.

2.3 Health and Wellness Data

With your explicit consent, the Application reads the following health and fitness data from Android Health Connect (and, on iOS, Apple Health / HealthKit): steps, distance, active calories burned, workouts/exercise sessions, and heart rate. The Application accesses this data on a read-only basis and never writes data back to Health Connect or Apple Health.

This data is used exclusively to: (i) display a per-session activity summary after you complete a booked course; (ii) show your progress and trends over time; and (iii) generate personalized fitness and nutrition (diet plan) recommendations. To provide these features, the data is transmitted securely to and stored on Champion Spirit's servers (hosted by Scaleway, within the EU). It is never used for advertising, never sold, and never shared with third parties for unrelated purposes. It is not shared with our payment or email providers.

Health data constitutes a "special category of data" under Article 9 of the GDPR and is processed solely on the basis of your explicit consent (Art. 9.2.a). You may withdraw consent at any time by disconnecting access in your device's Health Connect / Apple Health settings, and you may request deletion of this data at any time via the Application or by contacting us. Upon disconnection or deletion request, we delete the associated health data from our servers within 30 days, except where retention is required by law.

3. Purposes and legal bases of processing

Purpose

Legal Basis (GDPR)

Creation and management of your premium account

Performance of the contract (Art. 6.1.b)

QR code identification and access to partner services and venues

Performance of the contract (Art. 6.1.b)

Booking for sports and spa sessions, and integration with coaches and service providers

Performance of the contract (Art. 6.1.b)

Payment Management and Fraud Prevention

Performance of the contract / legitimate interest (Art. 6.1.b and 6.1.f)

Geolocation services to offer premium, nearby experiences

Consent (Art. 6(1)(a))

Premium Client Support and Inquiries

Legitimate interest / performance of a contract

Enhancement, security, and analytics of the Application

Legitimate interest (Art. 6.1.f)

Distribution of marketing communications

Consent (Art. 6(1)(a))

Compliance with legal and accounting obligations

Legal obligation (Art. 6.1.c)

4. Data Retention Period

We retain your data only for the duration necessary to fulfill the described purposes, after which it is permanently deleted or anonymized.

Data Category

Shelf life

Account Credentials

For the entire duration of the account, followed by deletion no later than 24 months after the last activity

Booking and Usage Data

Account duration, followed by archiving / deletion within 24 months

Financial Statements and Invoices

10 years (statutory obligation)

Payment Information

The duration of the transaction; any data retained by the payment provider is held in accordance with their own policy.

Prospecting and Marketing Intelligence

3 years from the date of last contact, or until consent is withdrawn

Technical Data and Connection Logs

Up to 12 months

Cookies and Tracking Technologies

Maximum 13 months

Retention Policy: upon expiration of these periods, the data is securely deleted or irreversibly anonymized. Certain data may be retained for longer periods if required by law or for the establishment, exercise, or defense of legal claims.

5. Recipients and Subcontractors

Your data may be communicated to the following categories of recipients, strictly within the limits of their professional needs:

  • authorized Champion Spirit personnel;

  • independent coaches and service providers (notably spa professionals), solely for the information required to perform the booked services;

  • our technical subcontractors: hosting provider Scaleway, payment processor Stripe, and email delivery tools Brevo;

  • administrative or judicial authorities when legally required.

We do not sell your personal data to third parties.

6. Data Transfers Outside the European Union

As Champion Spirit International Ltd. is established in the Bahamas, and certain service providers may be located outside the European Economic Area, your data may be subject to transfer outside the EU. Since the Bahamas does not benefit from an adequacy decision by the European Commission, these transfers are governed by appropriate safeguards, including:

  • Standard Contractual Clauses adopted by the European Commission;

  • and/or any other safeguard provided under Chapter V of the GDPR.

You may obtain a copy of these safeguards by writing to us at the contact address specified in Article 1.

7. Data Security

We employ sophisticated technical and organizational measures to safeguard your data against loss, unauthorized access, disclosure, or alteration. These measures include password and communication encryption, strict access controls, secure hosting, and continuous monitoring. As no system is entirely infallible, we cannot guarantee absolute security.

8. Your Rights

In accordance with the GDPR, you possess the following rights regarding your personal data:

  • right of access and information;

  • right to rectification;

  • right to erasure (“right to be forgotten”);

  • right to restriction of processing;

  • right to object, particularly to direct marketing;

  • right to data portability;

  • right to withdraw consent at any time, without retroactive effect;

  • right to define directives concerning the disposition of your personal data after your death.

To exercise these rights, please contact us at the address specified in Article 1. We may require proof of identity, and we will respond within one month.

Should you consider that your rights have not been respected, you have the right to lodge a complaint with the CNIL (Commission Nationale de l’Informatique et des Libertés, www.cnil.fr) or the supervisory authority of your country of residence.

9. Cookies and Tracking Technologies

The Application may employ cookies and similar technologies for operational purposes, audience measurement, and, subject to your consent, personalization and advertising. You may manage your preferences via the consent banner or through your device settings. Cookies that are not strictly necessary will only be deployed upon receiving your explicit consent.

10. Protection of Minors

The Application is not intended for individuals under the age of 15. We do not knowingly collect personal data from minors under 15 without the consent of a parent or legal guardian. If you believe a minor has provided us with their data, please contact us so that we may delete it.

11. Amendments to this Policy

We may update this Privacy Policy from time to time to reflect legal developments or changes to our services. The applicable version is the one published a the time of your use. In the event of any material modifications, we will notify you through appropriate channels.

12. Contact Us

For any questions regarding this Privacy Policy or the processing of your data: contact@championspirit.com, Champion Spirit International Ltd., Nassau (Bahamas).

Champion Spirit International Ltd., Privacy Policy, Version of June 17, 2026