Buenavista Tennis & Padel Club Privacy Policy GDPR & LOPDGDD Compliance

PUBLIC DOCUMENT Responsible: Adam Gunda privacidad.buenavista@gmail.com +34 617 558 541

1. Who is responsible for your data?

Responsible party: Adam Gunda

NIF: Z1273880F

Address: Carrer del Tudó 19, 03720 Benissa, Alicante, Spain

Privacy email: privacidad.buenavista@gmail.com

Phone: +34 617 558 541

No Data Protection Officer (DPO) has been designated, as this is not mandatory for the club’s activities. Full GDPR/LOPDGDD compliance is maintained regardless.

2. What data do we collect and where from?

We process only the data strictly necessary for each purpose (data minimisation principle, GDPR Art. 5.1.c).

2.1 Data provided via the website (contact forms)

• Identification and contact details: name and phone number.
• Content of your message or request: information you include when booking the bar/studio or requesting tennis or padel lessons.

Source: provided directly by the person concerned (GDPR Arts. 13 and 14).

2.2 CCTV (video surveillance)

• Images captured by cameras in interior areas (bar, kitchen, and studio).
• Images captured by cameras in exterior areas (entrances, car park, and sports courts).

Note: no special category data is intentionally captured. No facial recognition or biometric processing is used.

2.3 Incidental capture of adjacent public road (minimised)

To protect our perimeter and access points, certain exterior cameras may incidentally capture a minimal strip of the immediately adjacent public road. This is done under LOPDGDD Art. 22 and is limited to what is strictly necessary for security purposes. Camera angles and fields of view have been configured to minimise this as much as technically possible.

3. Purposes, legal basis & retention periods

Purpose	Legal basis	Data involved	Retention period
Managing booking/enquiry requests (bar, studio, lessons)	Consent (GDPR Art. 6.1.a)	Name, phone, message	Until request is resolved + 1 year
CCTV — Security of premises, assets and persons	Legitimate interest (GDPR Art. 6.1.f)	Video images, date/time	Maximum 30 days (then auto-deleted)
CCTV — Incidental public road capture	Legitimate interest (GDPR Art. 6.1.f + LOPDGDD Art. 22)	Video images	Maximum 30 days

4. Who do we share your data with?

We do not sell or share your personal data with third parties for commercial purposes. Data may be disclosed to:

• Law enforcement, courts, or competent authorities where legally required.
• Authorised club staff responsible for managing requests and bookings (contact form data only).
• Technical service providers (hosting, email, CCTV cloud storage) acting as data processors under a written contract (GDPR Art. 28). These providers are bound by the same GDPR obligations.

5. International transfers

No international transfers outside the European Economic Area (EEA) are intended by the club. However, where cloud-based services are used (CCTV storage, email hosting), the club verifies that any such providers maintain appropriate safeguards if data is processed outside the EEA.

6. Your rights

You have the following rights under GDPR and LOPDGDD:

• Right of access — to know what data we hold about you.
• Right to rectification — to correct inaccurate data.
• Right to erasure — to request deletion of your data.
• Right to restriction — to limit how we process your data.
• Right to data portability — to receive your data in a structured format.
• Right to object — to object to processing based on legitimate interest.
• Right to withdraw consent — at any time, without affecting prior processing.

To exercise any of these rights, contact: privacidad.buenavista@gmail.com

You also have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD): www.aepd.es

7. CCTV signage (first-layer information)

The club displays CCTV signs at all camera locations as required by law. These signs provide basic information about the video surveillance and direct individuals to this full privacy policy for further details.

8. Changes to this policy

This Privacy Policy may be updated to reflect changes in law or our practices. The current version will always be available on our website. Last updated: May 2026.