DATA PROCESSING AND PRIVACY POLICY
Last Updated: May 2026

1. INTRODUCTION
This Privacy Policy explains how IP Samofalov A.V. (hereinafter referred to as "the Organizer", "we", "us", or "our") collects, uses, and protects the personal data of participants and their legal guardians (hereinafter referred to as "the User", "you") in relation to the Isaac Cuenca Football Camp in Serbia.
We are committed to ensuring that your privacy is protected in accordance with the General Data Protection Regulation (GDPR) and applicable international data protection laws.

2. DATA CONTROLLER
The entity responsible for processing your personal data is:
  • Legal Entity: IP Samofalov A.V.
  • Tax ID (INN): 781009984488
  • Contact Email: info@legioner.pro

3. DATA WE COLLECT
We may collect the following information:
  • Guardian Information: Name, email address, phone number, and country of residence.
  • Participant Information: Full name, date of birth, gender, and clothing size (for the football kit).
  • Health Data: Allergies, dietary requirements (including Halal), and any medical conditions (necessary for the safety of the minor during the camp).
  • Travel Details: Passport information and flight schedules (for airport transfer coordination).
  • Media: Photos and videos taken during the camp (only with explicit consent).

4. PURPOSE AND LEGAL BASIS FOR PROCESSING
We process your data based on the following legal grounds:
  • Performance of a Contract: To manage your booking, hotel stay, and football training services.
  • Legal Obligation: To issue invoices and comply with Serbian tourist registration laws.
  • Vital Interests: To protect the health and safety of the minor in case of a medical emergency.
  • Consent: For marketing communications and the use of the participant's image in promotional materials (social media, website).

5. DATA SHARING AND TRANSFERS
Your data may be shared with trusted third parties only when necessary:
  • Hotel Junior Kopaonik: For accommodation and meal arrangements.
  • Insurance Companies: To activate the participant's sports insurance policy.
  • Coaching Staff (including Isaac Cuenca): To manage training groups and individual feedback.
  • International Data Transfers: As the Organizer is based in Russia and the camp is in Serbia, your data will be transferred outside the European Economic Area (EEA). We ensure adequate safeguards are in place to protect your information.

6. DATA RETENTION
We will retain your personal data only for as long as is necessary for the purposes set out in this policy, or to comply with legal, tax, or reporting requirements.

7. YOUR RIGHTS
Under GDPR, you have the following rights:
  • Access: To request a copy of the data we hold about you.
  • Rectification: To correct any inaccurate information.
  • Erasure ("Right to be forgotten"): To request the deletion of your data.
  • Withdrawal of Consent: To opt-out of marketing or photo/video usage at any time.
  • Data Portability: To receive your data in a structured, machine-readable format.
To exercise these rights, please contact us at info@legioner.pro.

8. SECURITY
We implement technical and organizational measures to secure your data against unauthorized access, loss, or alteration. Access to personal data is restricted to authorized personnel only.

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