Ass. Hwalmoodo Switzerland (“HMD Basel”, “we”, “us”) is an association under Articles 60 ff. of the Swiss Civil Code, based at Kleinhüningerstrasse 205, 4057 Basel, Switzerland. Contact: info@hmdbasel.ch. Data protection responsible: Franco D’Agostino.

We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP, in force since 1 September 2023) and, where it applies, the EU General Data Protection Regulation (GDPR).

HMD Basel is a group affiliated to A.S. Dilettantistica HMD Italia (“HMD Italia”). This policy applies to everyone: members, people who book a trial or ask about classes, and visitors of hmdbasel.ch. Where HMD Italia is also involved, which concerns only members affiliated with HMD Italia, this is stated explicitly.

The English text of this policy is authoritative.

1. Who is responsible

HMD Basel is the controller for all processing described in this policy.

For members affiliated with HMD Italia, the processing for HMD Italia’s activities is carried out under joint controllership between HMD Basel and:

• A.S. Dilettantistica HMD Italia, Via Castelvecchio 9, 00078 Monte Porzio Catone (RM), Italy.

HMD Basel and HMD Italia have divided their responsibilities in a joint controllership agreement (Art. 26 GDPR):

• HMD Italia handles sports and institutional registration, insurance cover and verification of medical fitness for members based in Italy, where these apply.
• HMD Basel handles technical instruction, the day-to-day running of the course, the collection and accounting of fees, and sports and institutional registration in Switzerland.

HMD Italia’s joint privacy notice is available on request at either contact address in section 6.

2. Categories of data processed

• Identity and contact data: name, surname, place and date of birth, address, email, telephone number, and the parent’s or guardian’s details for minors.
• Administrative and accounting data: membership and training plans, attendance, receipts and payments of membership and plan fees, all paid to HMD Basel.
• Health data: a medical certificate or information on fitness to take part, only where required, for example to register for a competition.
• Photographs and video recorded during training, seminars, gradings, competitions or events.
• Trial bookings and enquiries: name, email, phone, appointment details or the class you are interested in.
• Website statistics: anonymised page views, device type and referrer.
• Partner-app bookings: name, contact data and the classes you book through FitPass or ClassPass.
• Map on our website: when the embedded Google Maps map is displayed, Google receives your IP address and browser data.

3. Purposes and legal bases

Under the FADP, we process personal data only in line with its principles; where needed, the processing is justified as shown below. Where the GDPR applies, the matching legal basis is given in brackets.

Purpose	Data processed	Legal basis
Membership, training plans, course attendance and sports registration in Switzerland. With HMD Italia for members based in Italy: registration and insurance, where applicable.	Identity, contact and administrative data	Performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR)
Payments, tax and accounting obligations	Identity and accounting data	Contract; legal obligation under the Swiss Code of Obligations (Art. 6(1)(c) GDPR)
Verification of physical fitness and health protection, medical certificate and injuries, where required (for example to register for a competition). With HMD Italia for members based in Italy, where applicable.	Health data	Your explicit consent (Art. 9(2)(a) GDPR), together with any legal obligations governing sports health
Operational course communications, messaging groups and notices about lessons and gradings. With HMD Italia for affiliated members.	Contact data	Legitimate interest in running the course (Art. 6(1)(f) GDPR)
Club news, events and membership offers to members and people who booked a trial	Contact data	Legitimate interest or consent (Art. 6(1)(f) or (a) GDPR); you can opt out at any time
Registration for external events and competitions, at your request	Identity and contact data; where the event requires it, a medical certificate	Contract (Art. 6(1)(b) GDPR); for health data, your explicit consent
Publication of photographs and video of the season’s events on social media, websites or promotional material. With HMD Italia for affiliated members.	Images and recordings	Your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time
Trial bookings, enquiries and early registration for new classes	Contact data, appointment details	Steps you ask us to take before a contract (Art. 6(1)(b) GDPR)
Website statistics	Anonymised usage data	Legitimate interest in improving the website (Art. 6(1)(f) GDPR)
Bookings through partner apps (FitPass, ClassPass)	Name, contact data, booked classes and attendance	Legitimate interest in admitting you to class and settling with the partner app (Art. 6(1)(f) GDPR)
Map on our website, showing our location	IP address and browser data, processed by Google	Legitimate interest in showing how to find us (Art. 6(1)(f) GDPR)
Insights to improve the training experience, using AI tools	Attendance, participation and membership data, pseudonymised or aggregated where possible; never health data	Legitimate interest in improving classes and the club (Art. 6(1)(f) GDPR)

AI tools only support our decisions; decisions about you are always made by people. You can object to this use at any time (section 6).

4. Recipients

Personal data may be disclosed to third parties acting as independent controllers or as processors, only as far as needed for the purposes above.

Services HMD Basel uses:

• Payments: Payrexx processes payments and subscriptions (TWINT, debit and credit cards). We never see your full card details.
• Accounting: Zoho Books; tax advisers, accountants and banks where needed.
• Club platform: Linyup, hosted on Google Firebase and shared with HMD Italia for affiliated members. Access is restricted to authorised club officials.
• Club documents: Microsoft and Google cloud services.
• Trial booking and registration forms: Setmore and Notion.
• Website statistics: Umami Cloud (EU region). No cookies or personal identifiers; IP addresses are not stored.
• Partner apps: FitPass and ClassPass send us your booking and, where they require it, receive confirmation of your attendance. Their own privacy policies apply to your account with them.
• Map: the contact section of our website embeds Google Maps. When the map is displayed, Google receives your IP address and browser data and processes them under its own privacy policy.
• AI tools: the AI features built into our club platform (Linyup), processed in the EU. For further analysis we may use Claude (Anthropic), with pseudonymised or aggregated data only and with settings that exclude the use of this data to train AI models.
• Messaging and social media: WhatsApp for course groups; Instagram, Facebook and our website for photographs and video you consented to (Meta).
• Swiss sports federations and event organisers such as WAKO Switzerland, for sports registration in Switzerland or when you register for an event, and only the data required.

Where HMD Italia is involved (affiliated members only):

• HMD Italia itself, as joint controller.
• Italian sports federations, promotion bodies and insurance companies, for members based in Italy, where registration or insurance through HMD Italia applies.

An up-to-date list of processors is available on request. We do not sell your data or share it with unrelated third parties.

5. Retention

• Accounting and payment records: 10 years, as Swiss law requires.
• Identity, contact and membership data: for the duration of the membership and afterwards for as long as legal obligations require.
• Medical certificates: HMD Basel does not store them; it only passes them on for the purpose concerned. Where HMD Italia handles them for members based in Italy, they are kept for the certificate’s period of validity, normally one year, and in any case until the end of the sporting season.
• Photographs and video: until consent is withdrawn or erasure is requested.
• Trial bookings and enquiries: until they are no longer needed to follow up, unless you become a member.
• Website statistics: anonymised and aggregated only.
• Partner-app bookings: as long as needed to settle with the partner app; accounting records 10 years.

When the right to erasure is exercised, or when the retention periods above expire, the personal data are securely removed. Where complete erasure of certain data cannot be carried out immediately, because of technical constraints or automated backup copies, that data is made inaccessible and promptly put through an irreversible anonymisation process, so that you can no longer be identified.

6. Your rights and contact

You have the right to ask for access to your data, rectification, erasure, restriction of processing or to object to it, as well as the right to data portability and to withdraw any consent given. We answer access requests within 30 days.

• Contact: write to info@hmdbasel.ch.
• Where HMD Italia is involved: under the joint controllership agreement, HMD Italia is the single contact point: kwanjanim1959@gmail.com. You can still write to us; we forward requests about the joint processing to HMD Italia within 24 hours.

You also have the right to contact a supervisory authority:

• Switzerland: Federal Data Protection and Information Commissioner (FDPIC), www.edoeb.admin.ch.
• Italy, for HMD Italia’s processing: Garante per la protezione dei dati personali, www.garanteprivacy.it.

7. Data outside Switzerland

Some of the services above process data outside Switzerland, in the EU or the USA. We use them only where the destination has adequate data protection, or with appropriate safeguards such as certification under the Swiss–US Data Privacy Framework or standard contractual clauses.

Where HMD Italia is involved, HMD Basel and HMD Italia share data with each other. Italy is listed as a state with adequate data protection under Swiss law, and Switzerland is recognised as adequate by the European Commission.

You can ask us for details of the safeguards used.

8. Security

We protect personal data with appropriate technical and organisational measures:

• encrypted transmission (HTTPS)
• access limited to authorised club officials
• reputable cloud providers

9. Changes

We may update this policy to reflect legal or operational changes. The current version is always at hmdbasel.ch/privacy-policy, with its date. Members who have accepted this policy receive the updated version by email.