Last updated: 15 August 2026
This statement describes how Tmi Markus Aarne Pentti Sipilä ("we", "us", "Provider") processes personal data when we act as a controller under the EU General Data Protection Regulation (GDPR).
It applies to:
- B2B customer data — information about curling clubs and other organisations that use or negotiate to use the Curlingclubs.cc service, and about contact persons representing them.
- Platform identity data — user accounts and Commerce customer profiles (including billing name and address) shared across club sites on the platform.
- Competition data — public competition and results information that we process for curlingresults.cc and related cross-club results, statistics and data products.
This statement does not describe how our customer clubs process the personal data through this SaaS platform (memberships, bookings, event registrations and similar club records). For that processing we act as a processor; the club is responsible and provides its own privacy information. Our processor role is governed by the Data Processing Agreement with each organization.
1. Controller
| Name | Tmi Markus Aarne Pentti Sipilä |
| Business ID | 3497538-3 |
| Address | Kolapuuntie 5A, 02620 Espoo, Finland |
| Service | Curlingclubs.cc (hosted software for curling clubs) and related services including Curlingresults.cc |
Privacy contact: info@curlingclubs.cc
2. What this statement covers
2.1 B2B customer data
We process personal data about representatives of club customers and prospective customers in our commercial relationship, for example:
- contact persons' names, email addresses, phone numbers and job roles;
- organisation names, business IDs and billing or postal addresses;
- contract, subscription and invoicing records;
- support and sales correspondence (email and similar channels);
- technical and administrative contacts for the Service (e.g. manager accounts used to administer a club site, where we need to identify a natural person for billing, security or support).
We do not use club operational data (memberships, bookings, private contact details of members, etc.) for our own marketing or unrelated commercial purposes.
2.2 Platform identity across club sites
Curlingclubs.cc hosts multiple club sites, each on its own domain.
User accounts (login credentials and account email) are shared across club sites on the platform. A user who registers on one club's site can log in on another club's site with the same user account. We act as controller for this platform-level identity processing so that one login works across club tenants.
E-commerce customer profiles (billing name and address used at checkout) are one customer profile per user account, shared across club sites. If a user saves an address while shopping at one club, the same customer profile will be used when they shop at another club using the same platform, using the same user account. Each club uses that information only for its own sales and customer relationship according to their own privacy notice.
Person profiles (person records for memberships, bookings, event registrations and similar activities) are not automatically shared between clubs. A person profile is linked to specific club sites when it is created there or when the user voluntarily associates an existing person profile with another club's site (for example when participating in that club's event or competition). When a user associates a person profile with a club site, that club processes the profile under its own privacy notice. Club-specific operational data (such as memberships or bookings at one club) is not visible to other clubs.
Links to external player profiles: The platform may store optional mappings that link a person record to a player profile or identifier in an external system (for example Curling.fi, Curlingzone or World Curling), when a user or club enters them. These mappings are not limited to one club domain: if a mapping is added on one club site, it stays with that person record and follows the profile on every site that person is affiliated with, including other club sites on the platform and curlingresults.cc. Clubs remain controllers for collecting and using person data on their sites; we process and host the mappings as part of operating the Service. Those external services are operated by third parties under their own privacy notices.
We host and technically process this data as part of operating the platform. Clubs remain controllers for their domain-scoped operational processing; we describe our controller role here only for platform identity.
2.3 Competition data
Competition data means competition-related information that is intended to be public sports results information. It may include, for example:
- competition names, dates and categories;
- team names and rosters;
- player names and participation in games;
- schedules, scores, standings and statistics;
- derived rankings, benchmarks, aggregates and other statistics or data products built from that public results information.
Competition data is collected and published as part of organised curling competitions on the Curlingclubs.cc platform. Clubs publish results on their own sites; the same class of public result information may also appear automatically on curlingresults.cc, our multi-club results service.
Competition data does not include private fields such as member email addresses, phone numbers, birth dates, booking history or payment details.
Clubs remain controllers for their own publication of competition results and for informing their members. We act as an independent controller for cross-club publication on curlingresults.cc, aggregation, analysis and related data products, as described in this privacy notice.
3. Purposes and legal bases
| Processing | Examples | Legal basis (GDPR Art. 6) |
|---|---|---|
| Providing and administering the SaaS to club customers | accounts, configuration, service delivery | Contract |
| Invoicing and customer administration | billing, payment follow-up, contract records | Contract; legal obligation (accounting) |
| Customer support and communication | answering enquiries, incident handling | Contract; legitimate interest |
| Service security and abuse prevention | logs, access control, fraud prevention | Legitimate interest |
| Publishing public competition results on curlingresults.cc | multi-club results portal | Legitimate interest (public sports results and historical record) |
| Statistics, rankings and data products from competition data | aggregates, analytics, commercial products based on public results | Legitimate interest (public sports information and service development) |
| Platform user accounts and E-commerce customer profiles | single login and checkout identity across club sites on the platform | Legitimate interest (operating a shared multitenant service); contract with clubs where relevant |
| Legal compliance | tax, authority requests | Legal obligation |
Where we rely on legitimate interest, we balance our interests against the rights of data subjects. For competition data, the information is already public sports results material; our processing is limited to that class of data and supports transparency of competition history and cross-club results services.
We use consent only where required (for example optional cookies on our own website, if enabled).
4. Sources of data
- Directly from club representatives (contracts, email, support tickets, sign-up).
- From users who create or use accounts and Commerce customer profiles on club sites on the platform.
- From club use of the platform.
5. Recipients and subprocessors
We use subprocessors to host and operate the Service. An up-to-date list is published at:
https://curlingclubs.cc/en/privacy/sub-processors
Typical categories include hosting and email delivery. Clubs' own payment providers are not our subprocessors.
We may disclose personal data to authorities when required by law.
We do not sell personal data to third parties for their unrelated marketing.
6. International transfers
We aim to process personal data primarily in the EU/EEA.
Some subprocessors may process data outside the EU/EEA. Where required, we use appropriate safeguards such as the European Commission's standard contractual clauses or an adequacy decision. Details are described in our agreements with subprocessors and, where relevant, on the subprocessor list.
7. Retention
| Data | Retention principle |
|---|---|
| B2B contract and invoicing data | For the customer relationship and at least the statutory accounting period thereafter |
| Platform accounts and Commerce customer profiles | For as long as the account exists and the Service is operated; deleted or anonymised when no longer needed for identity or legal obligations |
| Support and sales correspondence | For as long as needed for the relationship and our legitimate business records; we do not routinely delete business email |
| Competition data and published results | Retained as a sports archive; participation and results are not removed from history when a person stops playing or a club ends its subscription, except where law requires otherwise |
| Derived statistics and data products | May be retained and updated as part of ongoing results services |
When a club ends its subscription, we delete or return club operational personal data processed on the club's behalf in accordance with the SaaS agreement and Data Processing Agreement. Competition data that we are entitled to retain under those agreements may continue to be published and used as described above.
8. Security
We implement appropriate technical and organisational measures to protect personal data, including access controls, encryption in transit, separation of club data in the multitenant service, backups and contractual requirements for subprocessors.
9. Your rights
Depending on the processing, you have the right to:
- access your personal data;
- request rectification of inaccurate data;
- request erasure, minimification or restriction of processing;
- object to processing based on legitimate interest;
- data portability, where applicable;
- withdraw consent, where processing is based on consent;
- lodge a complaint with a supervisory authority.
Competition data and sports history: Requests to erase or restrict processing of published competition results are assessed in light of the public nature of sports results and the integrity of the historical record. We do not generally remove or alter published results so that participation disappears from the archive. You may still contact us if you believe our processing of competition data is disproportionate in your case.
Club member data: If your request concerns membership, bookings, payments, person profiles (including links to external player profiles), or other operational data managed by a club on the platform, contact the club (they are the controller). We will assist the club as processor where required.
Platform login and checkout profile: Requests about your user account or Commerce customer profile (login email, billing address on the shared checkout profile) may be directed to us at info@curlingclubs.cc, unless the matter is handled by a club as part of your relationship with that club.
Supervisory authority (Finland):
Office of the Data Protection Ombudsman — https://tietosuoja.fi
Privacy requests: info@curlingclubs.cc
10. Automated decision-making
We do not use automated decision-making or profiling that produces legal or similarly significant effects on data subjects.
11. Children
Competition results may include the names of junior players in public competitions. Clubs are responsible for their own junior policies and notices. Public junior competition results are treated similarly to adult results because competition sport is public by nature.
12. Changes
We may update this statement when our services, subprocessors or legal obligations change. The current version is available on this page. Material changes may also be communicated to club customers where appropriate.
13. Related documents
| Document | Role |
|---|---|
| Subprocessor list | Subprocessors used for the Service |
| Club privacy notices on club websites | Controller information for club members and players |