Effective Date: September 9, 2025
Last Updated: July 20, 2026
Data Controller
Data controller and service provider:
- BOREAL SOLUTIONS LTD, UIC 208732972
- Registered seat and address: Republic of Bulgaria, Sofia (Capital), Stolichna Municipality, Sofia 1700, Lozenets district, 20 Todor Kozhuharov St., floor 2, apt. 9
- Correspondence address: Republic of Bulgaria, Sofia (Capital), Stolichna Municipality, Sofia 1700, Lozenets district, 20 Todor Kozhuharov St., floor 2, apt. 9
- VAT: BG208732972 — registered under Art. 97a of the Bulgarian VAT Act (no VAT registration for charging VAT on taxable supplies in Bulgaria)
- Email: privacy@supairnic.com
- Support: support@supairnic.com
- Phone: +359885552634
- Public registry entry: Entered in the Bulgarian Commercial Register (TRRULNC) under UIC 208732972
DPO: No DPO appointed. For privacy-related questions: privacy@supairnic.com
1. Introduction
Welcome to Supairnic ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App"). We are committed to protecting your personal information and your right to privacy.
We use your personal data only for the purposes and on the legal bases described in this Privacy Policy. For certain optional features — such as certain notifications, analytics settings, or location access — we may ask for separate consent, which you can withdraw at any time through the app or device settings.
2. Information We Collect
2.1 Personal Information You Provide
Account Information:
- Email address and password (for email authentication)
- Name (required for account creation)
- Date of birth (required during profile setup for age verification — the App is restricted to users 18 or older; see Section 7)
- City/Location (for matching with nearby users)
- Sports preferences and skill rankings
Social Authentication (Optional):
- Google Account information (name, email, profile picture) when using Google Sign-In
- Apple ID information (name, email) when using Apple Sign-In
- We only access basic profile information necessary for account creation
- You can choose to use email authentication instead of social login
Profile Data:
- Sports you play (Tennis, Badminton, Football, Squash, Padel, Table tennis, Basketball, Volleyball, Futsal, Boxing)
- Skill level rankings (A, B, C, or No Level)
- Match history and participation records
- User validation status for skill rankings
Trust and Reputation Data:
- Trust score (percentage based on event participation reliability)
- Events attended and successfully organized
- Cancellation penalties (when you cancel an event less than 2 hours before its start)
- No-show reports you submit about other participants and reports submitted about you (reporting user, reported user, event, and timestamp)
- Completion rate for events you organize
- This score affects your visibility and matching with other users
How the Trust Score works:
The Trust Score uses factors such as completed events (as a participant and as an organizer) and penalties. A no-show penalty is applied when a majority of an event's other participants report that you did not attend, or when the venue reports non-attendance for a booked event. Three no-show penalties within 30 days result in an automatic 7-day suspension from joining and creating events. These decisions are applied automatically based on the rules above, and you always have the right to obtain human review: contact support@supairnic.com and we will review whether the penalty was applied correctly. Reports you submit and reports about you are stored privately — other users never see who reported whom or how many reports exist — and are deleted once the event's attendance is finalized (24 hours after the event ends). A smaller penalty is applied for late disruptions: leaving an event, cancelling an event you organize, or removing a participant from an event you organize less than 2 hours before its start. These penalties decrease only your Trust Score and never lead to a suspension on their own — suspensions arise solely from repeated no-shows as described above. An organizer's late cancellation is not penalized when a participant has already left the event within the same 2-hour window. The Trust Score is not used for automatic account termination without human review.
Event and Activity Data:
- Events you create or join
- Location data for events you organize
- Participant interactions and communications
- Event dismissal preferences
Safety and Moderation Data:
- User reports you submit (including reported user ID, reason, and context)
- List of users you have blocked (stored privately and never shared)
Social Connections:
- Friend requests you send and receive
- List of users you are connected with as friends
- Friend connection history
- Friend-related notifications
2.2 Automatically Collected Information
Device and Usage Information:
- Device identifiers and technical information
- App usage patterns and preferences
- Session duration and frequency of use
- Error logs and crash reports
Device Identifiers:
Firebase Analytics automatically collects an App Instance ID to analyze usage patterns and app performance. This identifier is unique to your app installation and resets when you uninstall the app. We also collect device information (model, OS version, screen resolution, language settings) for compatibility and localization purposes. We do NOT collect advertising IDs (IDFA/AAID) or permanent device hardware identifiers. You can disable analytics via Settings → Privacy Controls → Analytics & Error Reporting.
Push Notification Data:
- Expo push token (stored to send you notifications about events and activities)
- Notification preferences (which types of notifications you want to receive)
- Notification delivery status (to ensure reliable notification delivery)
- You can disable push notifications at any time in your device settings
Location Information:
- Sports venue information sourced from publicly available sources (see Section 2.5)
- General location for matching with nearby activities
- For venues without a partner profile we store a technical place identifier (place ID) and venue information (name, address, coordinates, supported sports) sourced by Supairnic from publicly available sources
- For venues with a partner profile, the data shown is submitted by the venue itself
- Your personal location data is never shared with other users
No Location for Attendance:
We do not use background location tracking. Event attendance does not use your location at all: attendance is recorded automatically unless other participants report a no-show (see "How the Trust Score works" above).
Technical Data:
- IP address and network information
- Operating system and app version
- Performance and diagnostic information
2.3 Information from Third Parties
Social Validation:
- Skill rankings validated by other users
- Feedback and ratings from match participants
- Community-generated content and interactions
2.4 Venue Representative Data
If you register or claim a sports venue profile (venue account), we process:
- The representative's email (from your user account)
- The venue name and address stated in the claim request
- Additional data or documents, if requested to verify authority to represent the venue
- Venue data you submit after approval (photos, opening hours, contact details)
Purpose: verifying the claim request, creating and managing the venue account, partnership communication. Legal basis: contract (Art. 6(1)(b) GDPR) and our legitimate interest in verifying that venues are managed by authorized persons (Art. 6(1)(f) GDPR). Retention: while the venue account is active. Venue claim data may be retained for up to 12 months after rejection, termination, or suspected abuse, to the extent necessary to prevent fraudulent venue claims, protect legal interests, or comply with a legal obligation.
2.5 Publicly Available Venue Data
The App displays information about sports venues without a partner profile (name, address, coordinates, supported sports) sourced from publicly available sources. Where a venue is operated by an individual (e.g. a sole trader or independent coach), this information may constitute personal data.
- Source: publicly available sources; the data is not collected directly from the individual
- Legal basis: legitimate interest (Art. 6(1)(f) GDPR) — connecting athletes with suitable sports venues
- Storage: we store a technical place identifier (place ID) and the venue information we have sourced, for as long as the venue is available in the App
- Your rights: a venue representative may claim the venue profile or request correction/objection via support@supairnic.com or privacy@supairnic.com
3. How We Use Your Information
3.1 Primary Purposes
Service Delivery:
- Create and manage your user account
- Connect you with sporting events and activities
- Match you with users of similar skill levels
- Facilitate communication between participants
Event Management:
- Process event creation and participation
- Manage location-based event discovery
- Handle event cancellations and modifications
- Record attendance and process no-show reports (see "How the Trust Score works")
- Track participation history
Community Features:
- Enable skill ranking and validation system
- Facilitate user-to-user rankings and feedback
- Build reputation and trust within the community
- Prevent misuse and maintain service quality
3.2 Secondary Purposes
Service Improvement:
- Analyze usage patterns to enhance user experience
- Develop new features and functionality
- Optimize app performance and reliability
- Conduct research and analytics
Safety and Security:
- Detect and prevent fraudulent activities
- Monitor for inappropriate behavior
- Enforce our Terms of Service
- Protect user safety and community standards
Legal Compliance:
- Comply with applicable laws and regulations
- Respond to legal requests and court orders
- Protect our rights and legal interests
- Fulfill regulatory requirements
4. Information Sharing and Disclosure
4.1 Within the App Community
Public Information:
- Your name and city (visible to other users)
- Sports preferences and validated skill rankings
- Public events you create or participate in
- Match history and participation records
Limited Sharing:
- Event location data (only with event participants)
- Performance ratings (for skill validation purposes)
- Activity status and availability
- Your friend list is only visible to you (not shared publicly)
4.2 Third-Party Service Providers
We use technical service providers (Google Firebase / Google Cloud, Google Maps, Expo Notifications) and authentication providers (Google Sign-In, Apple Sign-In). The full list of recipients and their roles is set out in Section 10.2.
Partner Sports Venues:
- If you use features tied to a specific venue (e.g. a booking), the venue receives the data necessary to fulfil them (e.g. your name and booking details)
- Venues process this data as independent controllers for the purpose of providing the service
- We do not sell or rent your personal information
4.3 Legal and Safety Requirements
We may disclose your information when required by law or when we believe disclosure is necessary to:
- Comply with legal processes or government requests
- Protect our rights, property, or safety
- Protect the rights, property, or safety of our users
- Investigate potential violations of our Terms of Service
5. Data Storage and Security
5.1 Security Measures
Technical Safeguards:
- Encryption of data in transit and at rest
- Secure authentication using industry standards
- Regular security assessments and updates
- Access controls and user authentication
Operational Safeguards:
- Employee training on data protection
- Limited access to personal information
- Regular backups and data recovery procedures
- Incident response and breach notification protocols
5.2 Data Retention
Account Information:
- Retained for the duration of your account
- Deleted immediately upon account deletion — see Section 6.2 for the process
Activity Data:
- Event data and match history are retained after account deletion only to the extent necessary for the integrity of community functionality, abuse prevention, and protection of legal interests, subject to periodic review of the need for retention
- User identity in these records is replaced with "Anonymous" upon account deletion (see "De-identification" below)
- Event participation records maintained for system integrity
De-identification:
Some historical event and validation records are retained after account deletion in de-identified form (the name is replaced with "Anonymous" and personal profile data is erased). Where de-identification cannot reasonably exclude re-identification, these records are treated as personal data and stored only with appropriate safeguards and restricted access.
Backups and Technical Records:
Data removed from active systems may temporarily remain in backups, system logs, or security records for a limited period necessary for recovery, security, abuse prevention, and demonstrating compliance. This data is not used for active app functionality and is deleted or overwritten in accordance with internal retention schedules. As indicative maximum periods: backups — up to 90 days; security and system logs — up to 12 months, unless a longer period is required for a specific legal claim or legal obligation.
Chat Messages:
- Chat messages you sent in event chats are scheduled for deletion and removed within 30 days after account deletion
- During this period, messages may remain visible in existing chat threads for participants
- Chat messages are not retained indefinitely and are removed by scheduled cleanup
Validation Data:
- Validations you received: Permanently deleted upon account closure
- Validations you provided to others: Preserved but de-identified to protect community integrity
- Validator identity changed to "Anonymous" while preserving validation integrity
Social Connections:
- Friend connections: Removed from your account upon deletion
- Your friend connections in other users' accounts: Automatically removed when you delete your account
- Friend requests: Permanently deleted upon account closure
Technical Data:
- Analytics data aggregated and anonymized via Firebase
- Crash reports sent to Firebase Crashlytics for debugging
- Error logs not stored locally, sent to remote service only
- Local app preferences and cached data cleared upon account deletion
5.3 International Data Transfers
Some data may be processed outside your country of residence. The detailed framework for transfers outside the EEA and applicable safeguards is set out in Section 10.3.
6. Your Rights and Choices
6.1 Access and Control
Account Management:
- Update your profile information at any time
- Modify your sports preferences and skill levels
- Control event participation and visibility
- Manage notification preferences
Data Rights:
- Request access to your personal information
- Request correction of inaccurate information
- Request deletion of your personal information
- Request data portability (where applicable)
How to Exercise Your Rights:
To request access to, correction of, or a portable copy of your personal data, contact us at privacy@supairnic.com. We respond without undue delay, usually within 1 month. For account deletion, use the in-app deletion feature in Settings — this is processed immediately with no waiting period.
6.2 Account Deletion Process
Immediate Deletion:
- Account deletion is processed immediately upon confirmation
- No grace period - deletion cannot be undone
- Personal profile data permanently removed from all systems
- Local device storage automatically cleared
What Gets Deleted:
- Your profile information (name, preferences, skill levels)
- Validations you received from other users
- Your personal event participation history
- All locally stored app data and preferences
What Gets Preserved (De-identified):
- Events you created (marked as "Anonymous" creator)
- Validations you provided to others (marked as "Anonymous" validator)
- Community event history (your participation shown as "Anonymous")
- System integrity data required for proper app functioning
Process:
1. Go to Settings > Privacy Controls > Delete My Account
2. Confirm deletion through security prompts
3. Immediate processing begins automatically
4. You will be logged out and cannot recover the account
6.3 Location Services
Location Control:
- Enable or disable location services in your device settings
- Choose when to share location for specific events
- Location access is used for nearby event discovery
Withdrawal of Consent:
- You may withdraw consent for location sharing at any time
- Disabling location services may limit event discovery
- Some features may not function without location access
6.4 Communication Preferences
Notifications:
- Control push notifications in app settings
- Manage email communications (if any)
Marketing Communications:
We send marketing communications only where we have a valid legal basis, including your consent where required. You can opt out of marketing communications at any time through the app settings or via the instructions in each message. Operational messages related to your account, security, or events may be sent regardless of marketing preferences.
7. Children's Privacy
Our App is restricted to users who are 18 years of age or older. We do not knowingly collect personal information from users under 18. Age verification is required during account registration, and users under 18 are automatically blocked from creating accounts.
If you are a parent or guardian and believe your child under 18 has somehow accessed our service, please contact us immediately and we will promptly delete any associated data.
8. Third-Party Links and Services
Our App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party services you access through our App.
8.1 Google Services
We use Google services, including Google Maps / Places API and Firebase (Google Cloud), for location features, authentication, database, cloud functions, storage, and related infrastructure. Additional details about these providers as recipients and about international transfers are described in Section 10 below.
9. Users Outside the European Economic Area
The App is primarily directed at users in Bulgaria and the EEA. If you use the App from another jurisdiction, you may have additional rights under your local privacy laws. We do not sell personal information, and we apply the standards described in this policy to all users. To exercise any privacy right, contact privacy@supairnic.com.
10. European Privacy Rights (GDPR)
If you are located in the European Economic Area (EEA), your data is processed in accordance with Regulation (EU) 2016/679 (GDPR).
10.1 Purposes, Legal Bases, and Retention
- Account creation and maintenance - legal basis: contract (Art. 6(1)(b) GDPR) - retention: while your account remains active and until deletion under this policy.
- Event organization and participation - legal basis: contract (Art. 6(1)(b) GDPR) - retention: as described in the data retention section.
- Security, abuse prevention, and moderation - legal basis: legitimate interests (Art. 6(1)(f) GDPR) - retention: as necessary to protect the platform and users.
- Push notifications - legal basis: consent (Art. 6(1)(a) GDPR) and/or contract for operational notifications - retention: until withdrawn through device or app settings.
- Analytics and service improvement - legal basis: legitimate interests (Art. 6(1)(f) GDPR) and/or consent where applicable - retention: in aggregated or pseudonymized form under internal accountability periods.
- Legal obligations - legal basis: legal obligation (Art. 6(1)(c) GDPR) - retention: as required by applicable law.
- Venue account management and authority verification - legal basis: contract (Art. 6(1)(b) GDPR) and legitimate interests (Art. 6(1)(f) GDPR) - retention: while the account is active; rejected claim requests - up to 12 months.
- Displaying publicly available sports venue information - legal basis: legitimate interests (Art. 6(1)(f) GDPR) - retention: while the venue is available in the App (see Section 2.5).
10.2 Recipients and Categories of Recipients
- Google Firebase / Google Cloud - authentication, database, cloud functions, storage, app analytics, crash diagnostics, and related infrastructure.
- Google Maps - mapping and location services within the App.
- Expo Notifications - delivery of push notifications and push token management.
- Google Sign-In and Apple Sign-In - where you choose social sign-in.
- Partner sports venues - only data necessary to fulfil a service you request (e.g. a booking).
- Competent public authorities where required by law.
10.3 Transfers Outside the EEA
Some data may be processed outside the EEA by our service providers — primarily Google and Expo, which process data in the United States. These transfers are covered by appropriate safeguards: Standard Contractual Clauses (SCCs) and/or the adequacy decision under the EU-U.S. Data Privacy Framework, in accordance with the respective provider's data processing terms (Google Firebase Data Processing Terms, Google Cloud DPA, Expo DPA). A current list of providers is available upon request at privacy@supairnic.com.
10.4 Your Rights
- Right of access.
- Right to rectification.
- Right to erasure.
- Right to restriction of processing.
- Right to object.
- Right to data portability.
- Right to withdraw consent where processing is based on consent; withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
To exercise your rights, contact privacy@supairnic.com. We respond without undue delay, usually within 1 month.
10.5 Complaint to Supervisory Authority
You have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection (CPDP):
11. Device Technologies (SDKs, Identifiers, and Tokens)
The App uses the following device technologies:
Firebase Analytics (Google)
- Purpose: usage and performance analytics
- Optional: yes — disable via Settings → Privacy Controls → Analytics & Error Reporting
Firebase Crashlytics (Google)
- Purpose: crash diagnostics and reliability
- Basis: legitimate interest (app stability and security); limited together with analytics via the same setting
Push token (Expo)
- Purpose: delivery of notifications about your events and activities
- Control: via device or app settings
Google Maps
- Purpose: displaying the map and nearby venues
- Control: via the device's location permissions
Disabling certain technologies may limit parts of the App's functionality.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Non-material editorial or technical changes may take effect upon posting. Material changes that affect your rights, the categories of data processed, the purposes or legal bases of processing, or recipients will be communicated in advance via the App and/or by email, and where the law or the nature of the change requires it, we will ask for your explicit acceptance. The "Last Updated" date at the top of this policy always reflects the current version.
If you do not agree with the changes, you can stop using the App and delete your account before they take effect.
13. Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
The controller's full details are set out in the "Data Controller" section at the top of this policy.
Email: privacy@supairnic.com
Support: support@supairnic.com
We respond to data subject requests and privacy questions without undue delay, usually within 1 month.
14. Jurisdiction and Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Bulgaria. Any disputes arising from this Privacy Policy will be resolved through applicable legal channels in accordance with Bulgarian law.
This Privacy Policy is effective as of the date listed above and applies to all users of the Supairnic mobile application.
Last Updated: July 20, 2026