Privacy Notice

CombineWell is an online platform that organizations such as clubs, associations, training groups and communities use to run their membership: a public page, applications, member records and memberships. CombineWell is operated by SIA Sneeds. In this notice, “we” and “us” mean SIA Sneeds.

This notice explains how personal information is handled when you visit the CombineWell website, apply to an organization, use a CombineWell account or administer an organization.

When you apply to or belong to an organization that uses CombineWell, two parties are involved, each responsible for its own part:

• The organization decides what it offers, reviews applications and keeps its member records. For that information, the organization is generally the controller: it decides how the information is used. We process it on the organization's behalf, as its processor, to provide the platform.
• SIA Sneeds is the controller of what we use for our own purposes: CombineWell accounts and sign-in, the security of the platform, preventing abuse, our relationship with the organizations that use CombineWell, support, and meeting our legal obligations.

An organization's membership rules, fees and conditions are its own. Its contact details are on its public page.

• Applications: the membership chosen and the member's name, with their email address, phone number and date of birth when given. When someone applies for another person: the applicant's name, email address and phone number, and their relationship to the member (parent or guardian, or other). Who the organization should contact and, for a paid membership, who pays, with that person's name, email address and phone number when it is someone else. An optional message to the organization. When the applicant confirmed the details, the versions of this notice and the Terms of Use that applied, and the language used.
• Members: once an application is accepted, the organization's member record of that person (name, email address, phone number and date of birth, as given in the application) and the membership: its type, status, terms and dates.
• Accounts: your email address, password and language; for someone who creates an organization, also their name and the organization's details. When you sign in, we keep records of your sessions, including the network (IP) address and browser they came from, to keep your account secure.
• Administrators: which organizations an account administers, and its role. Changes administrators make to their organization's records are kept in that organization's activity history.
• Payments: the amount, currency, status and times of each payment attempt, refund and dispute, and the payment provider's reference for them. Card details are entered on the payment provider's own checkout page: we do not receive full card numbers or card security codes.
• Emails: for the emails we send about applications and payments, the recipient's email address and language, and the organization, membership type and price the email names.
• Website visits: when you open a page, our hosting provider receives your network (IP) address, your browser details and the address of the page, as any website host does.
• Abuse prevention: counts of recent submissions per email address and per network address, stored as one-way hashes rather than as the addresses themselves.
• Messages to us: what you write and your contact details.

• to provide the platform an organization uses: its public page, applications and decisions, member records and memberships;
• to create and protect CombineWell accounts and let you sign in;
• to show you, in My CombineWell, the memberships linked to your account and the applications you sent or saved;
• to email the contact an application names about that application and its payment;
• to take payments through the payment provider, when an organization uses online payments;
• to keep the platform secure, prevent abuse and investigate problems;
• to answer questions and support organizations;
• to meet our legal obligations.

A parent, guardian or another person can apply on someone else's behalf, including for a child. A child does not need a CombineWell account to become a member.

Whoever applies for someone else confirms that they are allowed to provide that person's information.

The applicant, the contact, the payer and the member are separate roles, and each gives only what it says: applying for someone, being their contact or paying for them gives no access to that person's memberships in My CombineWell.

Our emails go to the contact the application names and mention only the organization, the membership type and the price, never the member.

• The organization you apply to sees your application and keeps its own member records. It cannot see which CombineWell account, if any, sent the application.
• No other organization can see it, or tell that it exists. Organizations cannot link or compare their records of the same person.
• You, in My CombineWell: the memberships linked to your account and the applications you sent while signed in or saved to it.
• Our service providers, which process information on our behalf to run the platform. They are listed on the Subprocessors page.
• The payment provider, for an organization's online payments, partly under its own privacy policy (see the same page).
• Authorities, where the law requires us to disclose information.

The CombineWell database is hosted in the European Union. Some of our service providers also process information outside the European Economic Area, for example in the United States. You can ask us which safeguards apply to a provider.

• Applications, member records and memberships are kept while the organization uses CombineWell, and are deleted when the organization's owner deletes the organization.
• Records of payments, refunds and disputes are financial records and are kept. An organization that holds them cannot be deleted yet.
• Your CombineWell account is kept until it is deleted. Account deletion is not currently available in the app. You can contact us to request deletion; we will handle the request according to the records and legal obligations that apply.

Fixed retention periods are not yet set for every kind of information. When they are, this notice will say so.

Data protection law, including the EU General Data Protection Regulation, gives you rights over your personal information. Depending on the situation, you can ask to access it, correct it, delete it, restrict its use or receive a copy to take elsewhere, and you can object to some uses of it.

Information an organization holds about you, such as an application or a member record: contact that organization, which decides about its records. You can also write to us, and we will pass your request on to the organization or help it respond.

Your CombineWell account and what we use for our own purposes: write to us at hello@combinewell.com. We may need to confirm who you are before acting on a request.

You can also complain to a data protection supervisory authority. In Latvia, this is the Data State Inspectorate.

CombineWell shows no advertising and uses no analytics, advertising or tracking cookies.

To work, the app keeps a few things in your browser's storage:

• your language choice;
• your sign-in session, while you are logged in;
• a private link to save an application to your account, until it is used or expires (30 days at most);
• a payment link, in the current browser tab only.

Pages show fonts and icons from Google Fonts. To load them, your browser connects to Google, which receives your network (IP) address and browser details. Google says it does not set cookies for this or use the information to build profiles: see its Google Fonts privacy FAQ.

Our safeguards include:

• access rules in the database that keep each organization's records apart from every other organization's;
• private links (to save an application or to pay) that are stored only as one-way hashes;
• keys for the payment provider and the email service that stay on our servers and never reach your browser;
• card details entered only on the payment provider's checkout page.

No system is completely secure. If you think something is wrong, write to us.

When this notice changes, we publish the new version here with its effective date. Each application records the version that applied when it was sent.

Write to SIA Sneeds at hello@combinewell.com, or by post to the registered address above.