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PRIVACY POLICY

Last Updated: July 23, 2026

At Cupidanza ("we," "us," or "our"), we respect your privacy and are committed to protecting your personal data. This policy details how we process personal data in full compliance with:

  • The General Data Protection Regulation (EU) 2016/679 (GDPR).
  • The Belgian Data Protection Act of July 30, 2018 (Wet van 30 juli 2018 betreffende de bescherming van natuurlijke personen met betrekking tot de verwerking van persoonsgegevens).
  • Book VI of the Belgian Code of Economic Law (Code de droit économique / Wetboek van economisch recht) governing market practices, consumer protection, and electronic commerce.

1. DATA CONTROLLER IDENTIFICATION

The Data Controller responsible for your personal data under the GDPR is:

  • Entity Name: Shawne Applebee
  • Registered Office Address: Titianstraat 13, 1000 Bruxelles
  • VAT Number: BE0627.798.648
  • Data Protection & Privacy Contact: [email protected]

2. TYPES OF PERSONAL DATA WE COLLECT

Depending on how you interact with Cupidanza, we collect and process the following categories of personal data:

A. Customers

  • Identity & Contact Data: Name, email address, phone number, delivery address, billing address, and language preferences (French or English).
  • Transactional & Order Data: Purchases of dance apparel, shoes, accessories, or event tickets; payment statuses, transaction logs, order histories, and withdrawal/return requests under EU consumer law.
  • Ticketing & Check-In Data: Unique QR code ticket tokens, event attendance logs, and ticket validation timestamps collected via our ticket scanner app (CupiScanner).
  • Technical & Usage Data: IP addresses, browser types, operating systems, device identifiers, app usage statistics, log files, and cookie identifiers.

B. Professionals

  • Business Identification Data: Business/trade name, legal representative details, physical business address, email, phone number, and KBO/BCE/VAT numbers.
  • Financial & Payout Data: Bank account details (IBAN/BIC), billing invoices, payout records, and tax-related documentation.
  • Listing & Communication Data: Inventory listings, event details, and communications routed through our marketplace messaging channels.

Payment Security Note: Payment card details (credit/debit card numbers, CVVs) are processed directly by our PCI-DSS compliant payment service providers (e.g., Stripe, Bancontact, PayPal) and are never stored on Cupidanza servers.

3. PURPOSES AND LEGAL BASES FOR DATA PROCESSING

Under Article 6 of the GDPR, we process your personal data based on the following legal grounds:

 

Processing Purpose

Legal Basis (GDPR Art. 6)

Primary Data Categories

Account Creation & Management: User registration, customer profiles, and authentication.

Performance of a Contract (Art. 6(1)(b))

Identity, Contact, Account Credentials

Marketplace Orders & Order Fulfilment: Processing purchases, coordinating shipping with sellers, and handling returns or statutory withdrawal rights.

Performance of a Contract (Art. 6(1)(b))

Identity, Contact, Order Data, Delivery Address

Event Ticketing & Venue Access: Issuing event tickets, generating QR tokens, and conducting venue check-ins via CupiScanner.

Performance of a Contract (Art. 6(1)(b))

Identity, Contact, Ticket Token, Scanning Logs

Payment, Payouts & Bancontact Processing: Executing checkout transactions and vendor earnings disbursements.

Performance of a Contract (Art. 6(1)(b))

Financial Data, Transaction Records

Accounting & Statutory Compliance: Invoicing, statutory book-keeping, VAT filings, and compliance with Belgian commercial and anti-money laundering (AML) laws.

Legal Obligation (Art. 6(1)(c))

Identity, Financial, Transactional Data

Fraud Prevention & Platform Integrity: Verifying ticket authenticity, detecting duplicate redemptions, preventing platform abuse, and maintaining IT security.

Legitimate Interest (Art. 6(1)(f))

Technical Data, Usage Logs, Ticket Scans

Direct Marketing & Newsletters: Sending promo codes, dance apparel arrivals, and event updates.

Consent (Art. 6(1)(a)) or Legitimate Interest (Soft Opt-in for existing buyers)

Contact Data, Marketing Preferences

4. SHARING AND DISCLOSURE OF DATA

To operate our marketplace platform, we share personal data on a strictly necessary basis with:

  1. Marketplace Sellers & Professionals: To fulfil physical orders (e.g., dance shoes or garments), relevant delivery details and customer names are shared with the fulfilling merchant.
  2. Event Organizers & Venue Staff: When you purchase event tickets, your name, ticket token, and entry status are shared with the event organizer and staff operating CupiScanner for admission control.
  3. Third-Party Data Processors:
    • Payment Gateways: Payment providers supporting EU and Belgian payment methods (e.g., Bancontact, Stripe, PayPal, Klarna).
    • Logistics & Postal Carriers: Shipping partners (e.g., Bpost, DHL) for parcel delivery and tracking.
    • Cloud & Software Infrastructure: Hosting providers, database management systems, and web application firewalls.
    • Communication Tools: Transactional email engines and customer support platforms.
  4. Legal & Regulatory Authorities: When legally mandated under Belgian or EU law, court orders, or requests by tax and judicial authorities.

5. INTERNATIONAL DATA TRANSFERS

Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate transfer mechanisms under Chapter V of the GDPR are implemented, such as:

  • Transferring data to non-EEA countries that have received an Adequacy Decision from the European Commission.
  • Entering European Commission-approved Standard Contractual Clauses (SCCs) alongside supplemental technical and organizational security measures.

6. DATA RETENTION & BELGIAN STATUTORY PERIODS

We retain personal data only for as long as needed to fulfil the purposes outlined in Section 3, adhering to Belgian legal retention mandates:

  • Customer Account Data: Retained for the lifetime of your active account. Upon an account deletion request, personal data is purged or anonymized within 30 days, unless statutory preservation rules apply.
  • Accounting, Tax & Transaction Records: Retained for 7 years (or up to 10 years for corporate tax audit purposes) following the close of the financial year, in accordance with Belgian accounting and tax laws.
  • Consumer Dispute Data & Warranties: Retained for up to 2 years to account for the legal guarantee period under the Belgian Code of Economic Law.
  • CupiScanner & Event Logs: Retained for up to 90 days post-event to settle ticket disputes or fraud claims, after which logs are deleted or fully anonymized.
  • Direct Marketing Data: Processed until you opt out, unsubscribe, or withdraw your consent.

7. AUTOMATED DECISION-MAKING AND PROFILING

Cupidanza does not utilize automated decision-making or profiling algorithms that produce legal or similarly significant effects on you as defined under Article 22 of the GDPR.

Any personalized recommendations (such as suggested dance events or apparel) are based on basic browsing interactions and do not impact your contract terms, pricing, or legal status on the platform.

8. YOUR GDPR RIGHTS & LODGING A COMPLAINT

Under Articles 15 – 22 of the GDPR and the Belgian Data Protection Act, you possess the following rights:

  • Right of Access (Art. 15): Request confirmation and a copy of the personal data we hold about you.
  • Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
  • Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your personal data where processing is no longer lawful or required.
  • Right to Restriction of Processing (Art. 18): Request that we temporarily halt the processing of your data under specific statutory conditions.
  • Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, and machine-readable format.
  • Right to Object (Art. 21): Object to processing based on legitimate interests or for direct marketing purposes.
  • Right to Withdraw Consent: Revoke consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise your rights, email us at [email protected]. We will process and respond to your request within one calendar month maximum.

Right to Lodge a Complaint with the Belgian Supervisory Authority

If you believe that our processing of your personal data infringes applicable data protection laws, you have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit (GBA) / Autorité de protection des données (APD)):

9. COOKIES & TRACKING TECHNOLOGIES

Our platform uses essential, functional, analytical, and marketing cookies.

  • Strictly Necessary / Essential Cookies: Required for technical operations, language preferences, shopping cart retention, and secure checkout navigation. These do not require user consent.
  • Analytical & Marketing Cookies: Implemented only after you grant explicit consent via our interactive Cookie Consent Banner (in compliance with ePrivacy directives and GBA guidance).

You can modify your cookie settings, view detailed vendor lists, or withdraw consent at any time via the "Cookie Preferences" link in our website footer.

10. SECURITY OF YOUR DATA

We implement appropriate technical and organizational measures to ensure a level of security suited to the risk of processing. These include:

  • End-to-end SSL/TLS encryption for all transmitted web traffic and API endpoints.
  • Tokenized ticket authentication to prevent unauthorized duplicate ticket access via CupiScanner.
  • Restricted access controls and mandatory authentication for internal staff and marketplace sellers.

11. CHILDREN'S PRIVACY

Cupidanza does not intentionally collect or process personal data from individuals under 16 years of age without verified consent from a parent or legal guardian. If we discover that a minor under 16 has provided us with personal data without appropriate authorization, we will promptly delete such information.

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy to reflect changes in regulatory standards, legal interpretations, or platform functionality. Updated versions will be published on this page with a revised "Last Updated" date. For material updates affecting your rights or data usage, we will notify you via email or a notice on Cupidanza.app.