Privacy Policy

Last updated: 9 November 2026 · Data controller: Witram Badminton ASBL, Luxembourg

This policy explains what personal data the Witram Badminton app ("the app") processes, why, and the rights you have under the EU General Data Protection Regulation (GDPR). Your club may be a joint controller for the data you share within it (see "Clubs" below).

1. Who we are

Witram Badminton ASBL — a non-profit association registered in Luxembourg. Registered office: [TODO: address]. RCS no.: [TODO]. Contact: privacy@witram.lu.

2. Data we process

Data	Why	Legal basis
Email address	Account identity (sign-in)	Contract
Name	Member profile and the statutory ASBL member list	Contract / legal obligation
User ID	Your record in the club database	Contract
Date of birth	Age-of-consent gate (GDPR Art. 8); age categories for rankings; the 18+ gate for the Community's members-only area	Legal obligation / consent
Guardian's email address (under-16s only)	Sending the parent or guardian the consent link	Legal obligation (GDPR Art. 8)
Activity data	Bookings, tournament entries, rankings, tactical boards, volunteer shifts and hours, event RSVPs, and — for admins — the club ledger	Contract / legitimate interest
Payment records	A record that a payment occurred: its reference, amount and status (never your card number)	Contract / legal obligation (accounting)
Community data (adults who join)	Membership, vouches, points, help requests, messages, reports and blocks — see Section 5	Contract; legitimate interest for safety and moderation; for a deleted account's messages, the other participants' legitimate interest in keeping their conversations
Device push token	Delivering notifications you have allowed	Consent (you allow notifications in iOS)

3. Sensitive data, handled with extra care

On-device swing analysis

Swing analysis uses the camera (computer-vision pose estimation) and motion sensors (stroke telemetry). This processing happens on your device. Video and motion data do not leave your device unless you explicitly enable cloud sync or club media sharing (GDPR Art. 9 explicit consent). The default is local-only.

Minors

In Luxembourg the digital age of consent is 16. Accounts for under-16s require approval by a parent or guardian before they become active. A time-limited verification link is sent to the guardian's email; unapproved minor accounts are automatically purged after 30 days. See our support page if you need a link resent. Members under 18 cannot join the Community's members-only area (the Trust board and Messages), and no adult can message a minor through the app.

Health details in help requests

A help request could reveal something about your health. When you write one, the app asks you to keep it general and not to share medical details; money requests use a fixed list of non-medical reasons as an optional tag.

4. Payments

Where in-app payment is available, real-world payments (court fees, tournament entries, gear, services, memberships) are processed by a third-party payment provider, Payconiq. Community money — money help between members and club causes — goes through Mangopay (see Section 5). We store a record that a payment occurred, its reference, amount and status; card and bank details are handled by the provider, not by us. Digital subscriptions (Pro/Elite tiers) are processed by Apple via the App Store; we never see your payment card.

5. Community

The Community hub brings together club causes, volunteering and, for adults, a members-only area: the Trust board (help requests between members) and Messages. Everything is scoped to your own club.

Joining: adults only, by vouching

The members-only area is for active club members aged 18 or over, checked from your date of birth when you join. You get in only when an existing community member vouches for you. To ask, you get a short vouch code (and a QR code of it) that is valid for 15 minutes; a member who knows you scans or types it, sees your first name to check it's you, and vouches. You then accept the community guidelines. We record who vouched for whom. Vouch codes and failed-code counters are deleted within about 75 minutes; a vouch you don't answer expires after 14 days. If a member is banned within 6 months of joining, the member who vouched for them loses points and cannot vouch for 6 months.

Points and recognition

You earn points for time and money you give (favours, volunteer shifts, contributions). The app shows your points only to you; they are stored with your community membership, which club admins can access to run the community. There are no rankings or leaderboards, for members or admins. Other club members can see your milestone badges, any dedication you add, and your trust title (for example "Host"), shown with your short name (first name and last initial). A history of your own contributions (kind, points and amount, never who received the help) is visible only to you. Optional thank-you notes are visible only to the helper they thank; a host's welcome message is visible to the host and the newcomer.

Help requests and co-signers

A help request (its title and details) can be seen by the active community members of your club while it is open or in progress. A money request first stays private to you and the two members you name as co-signers. Once both have co-signed it opens, and from then on the co-signers' identities are visible to your club's community members together with the request. Contributors cannot see other contributors' names. A request is deleted 24 hours after it is fulfilled, cancelled or expires; open requests expire 30 days after opening, and a money request that is never co-signed expires after 14 days. What remains afterwards contains no title, details or link to the person helped: the giver's contribution entry, and a payment record with a generic description ("Community support") kept for the statutory accounting period.

Payments through Mangopay

Money help and club causes are paid through Mangopay, a licensed electronic-money institution. Witram never holds the funds. To receive money you verify your identity with Mangopay. Mangopay is an independent controller for identity verification (KYC) and anti-money-laundering checks, and keeps those records under its own legal obligations and privacy policy. Your bank details for payouts (IBAN, account holder, address, nationality) pass through our servers to Mangopay in a single call and are not stored by us. We receive and keep: Mangopay's references for your account, your verification status, the last 4 digits of your IBAN, and the amounts and status of pay-ins, payouts and refunds. Your pledges to club causes are visible to you and your club's admins; the club sees each cause's paid total and the short names of backers who didn't choose to stay anonymous. Money features are only available where they have been switched on for your club.

Messages

Messages are member-to-member chats between community members of the same club: the club lounge (every member; you can mute or leave it), direct and group chats, and help-request threads between the person asking and their helper. Messages are text only. Participants see when others last read the chat, and you can edit or delete your own message for 15 minutes after sending it.

Messages are encrypted in transit (TLS) and at rest (Google-managed) and access-controlled per participant. They are not end-to-end encrypted: Witram's backend can technically read them, which moderation relies on. Club admins cannot read chats they are not part of; they see a message only when it has been reported or flagged by the content filter (below).

Retention: a help-request thread becomes read-only when the request closes and is deleted 7 days later. All other messages are deleted 12 months after they are sent. Leaving the community, a suspension or a ban removes you from your chats.

If you delete your account: the messages you sent stay visible to the people in those chats, shown as from “Deleted member”. Your name, photo and profile are removed, and nobody can reply to you. They are still deleted on the schedule above (12 months after sending; help-request threads 7 days after the request closes). In a chat where someone had blocked you, your messages are deleted instead, and the other person in a direct conversation can delete it at any time. Our legal basis is the legitimate interest of the other participants in keeping their own conversations (GDPR Art. 6(1)(f)).

Safety and moderation

• Report — you can report a message, a help request or a member. The reported content is copied into the report as a snapshot, so it can be reviewed by your club's admins and kept as evidence even after the original is deleted. Reports are kept until they are resolved and for 90 days afterwards.
• Block — blocking is silent: the person isn't told. It hides their messages and requests from you, prevents new direct chats either way, and stops notifications about them.
• Automated content filter — message and request text is checked on our servers against a list of objectionable terms. A match only flags the content for human review by your club's admins; the filter never blocks or hides anything, and every decision is taken by a person.
• Moderation actions — after review, admins can dismiss a report, warn a member, suspend them from the community (temporarily) or ban them (permanently, which also removes them from all chats). Admins can also suspend a member's ability to vouch. Warnings and suspensions are shown to the member in the app.
• A member is never told who reported them.

Push notifications

If you allow notifications, we store your device's push token so we can notify you of new messages, vouches, co-sign requests and accepted help requests. Notifications are sent through Firebase Cloud Messaging (Google) and Apple's push service. By default a message notification shows no preview: only the sender's name and the chat label (for example "Club lounge" or "Help request"). A setting in Messages turns previews on. Other community notifications carry a first name and what happened, never the content of a request. You aren't notified about people you have blocked. Your token is removed when you sign out. Push is not used for tracking or marketing.

6. Device permissions

• Camera — on-device swing analysis, and scanning vouch codes.
• Bluetooth — unlocking the court/hall door where your club uses it.
• Notifications — message and community notifications (see Section 5).
• Local network — discovering nearby devices for multi-camera analysis.
• Motion (Apple Watch) — wrist stroke telemetry for swing analysis.
• Photos / Calendar — only when you choose to save an exported tactical board, or add a club event or volunteer shift to your calendar.

Each permission is requested in context and can be changed in iOS Settings at any time.

7. Clubs (B2B)

Witram is provided to badminton clubs. Your club is a controller (or joint controller) of the member data processed within it; Witram Badminton ASBL provides the platform. Where required, a data-processing agreement (DPA) governs the relationship between a club and Witram.

8. Where your data lives, who receives it & how long we keep it

Data is stored and processed using Google Firebase (Firestore, Authentication, Cloud Functions and Cloud Messaging), with access restricted by server-side security rules. Your app data, files and photos are stored in the European Union (Firestore in Google's eur3 multi-region, Belgium and the Netherlands; file storage in Belgium), and our server functions run in Google's Belgium region (europe-west1). Some processing still takes place outside the EU/EEA: Firebase Authentication (your email address and sign-in data) is a global Google service, and push notifications are delivered through Google and Apple. Contact us for information about the safeguards that apply to these transfers.

The service providers that process data for us or receive it are: Google (Firebase, including Firebase Cloud Messaging), Apple (App Store subscriptions and push delivery), Payconiq (court and club payments) and Mangopay (community money; an independent controller for KYC and anti-money-laundering). Your club and, within the Community, other members see only what is described above.

We keep your data for as long as your membership is active and as required by Luxembourg association law, then delete or anonymise it. Specific periods:

• Unapproved minor accounts: 30 days.
• Payment records: the statutory accounting period.
• Help requests: 24 hours after they close. Help-request threads: 7 days after the request closes. Other messages: 12 months after they are sent.
• Vouch codes: about 75 minutes. Moderation reports: until resolved, plus 90 days.
• Mangopay's own KYC and payment records: as Mangopay's legal obligations require.

You can request deletion sooner (see Section 10).

9. What we don't do

No advertising. No cross-app/website tracking. No third-party analytics or advertising SDKs. No rankings or leaderboards of community members. We do not sell or rent personal data.

10. Your rights

Under the GDPR you may access, correct, export (portability), or delete your data, object to or restrict certain processing (including processing based on legitimate interest, such as moderation), and withdraw consent at any time (e.g. turning off cloud sync or notifications). To delete your account and data, see Account & data deletion, or email privacy@witram.lu.

Community data on erasure. When your account is erased, we delete your community membership, your open help requests, vouches you gave or received, vouch codes, thank-you notes you received or wrote, your badges and contribution counts, welcome messages you sent or received, award nominations of you, moderation notices, the Mangopay references and bank-account details we hold for you (the last 4 digits of your IBAN), blocks you made and blocks of you, your push tokens and your pledges that were not paid. We remove you from every chat. The messages you sent stay visible to the people in those chats, shown as from "Deleted member", until they are deleted on the normal schedule (see Messages above), except in chats where someone had blocked you, where they are deleted; nobody can reply to you. Records that others or the law still need are anonymised instead (your name removed, your account identifier replaced by "erased", amounts and dates kept): payments and refunds, the contribution and payout trail, pledges that were paid or are being paid, played court bookings, shop orders and service bookings, posts and events you published for the club, and coaching notes you wrote. Your name is removed from other members' dedications and from cause backer lists. Reports you filed lose your name; reports filed about you are kept as moderation evidence until 90 days after they are resolved, then deleted. Board-of-directors records keep your name where Luxembourg ASBL law requires it. Erasure is refused while you have an open money request holding funds or a payout still pending. Mangopay keeps its own KYC and payment records under its anti-money-laundering obligations, as an independent controller. Full details: Account & data deletion.

You also have the right to lodge a complaint with the Luxembourg supervisory authority, the CNPD.

11. Changes

We'll update this page when our practices change and revise the date above. Material changes affecting you will be surfaced in the app.

Questions? privacy@witram.lu