Privacy Policy

We take your privacy very seriously and treats all your personal data with great care. Pemp inc., a Delaware company, having a registered office at 19C Trolley Square, Delaware, the United States of America (hereinafter the “Company”, “we”, or “us”) processes and collects personal data from the individual who may be a visitor, user, consumer or camp organizer (hereinafter – “you” or “your”) through the website https://bjjcampfinder.com (hereinafter the “Website”).

This Privacy Policy governs the processing of personal data through the Website. The Website enables you to find, compare, book, offer or publish Brazilian Jiu-Jitsu camps and vacations anywhere in the world, and consume or provide additional services.

1. Legal grounds for the processing of personal data

1.1. There are some legal grounds for the processing of your personal data and we count on them to process your personal data. We use the main three bases to process your personal data: contracts, legitimate interests, and consent.

1.2. Contract – the legal ground for the processing when your personal data is necessary for us to perform a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

1.3. Legitimate Interests – the legal ground why the processing your data is necessary which is based on our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests and those interests have a specific purpose, they are necessary, and they are balanced.

1.4. Consent – your clear agreement to the processing of your personal data for a specific purpose.

1.5. Some applicable laws may indicate other legal grounds for the processing and when applicable we will count on such grounds.

2. Consent rules

2.1. If you have given consent to the processing of your data you can freely withdraw such consent at any time by contacting us or performing specific actions.

2.2. If you do withdraw your consent, and if we do not have another legal basis for the processing of your data, then we will stop the processing of the personal data and may delete in specific situations, including in case if you request the deletion of your personal data and we are obliged to delete such personal data.

2.3. If we have another legal basis for the processing of your data, then we may continue to do so, subject to your legal interests and rights.

2. The categories and purposes of personal data processed

2.1 Reservation information

In order to sign of any of the listed camps on the Website, you are required to enter certain information about yourself. The following information is obligatory and visible to camp organizers to identify you:

– First and Last Name;

– Email Address;

– Phone number.

Legal ground: contract.

2.2. Camp information

In order to register for a camp, we need to know your first and last name, email, phone, your experience.

Legal ground: contract.

2.3. Content

By using the Website in order to write a review you can make certain information available about yourself, such as your name, photo, place of residence, athlete information, and other “about you-information”. This information could include personal data. Once such information is submitted, this is visible for other users on the Website.

Legal ground: consent.

2.4. Payment information

The Company may, for the payment purposes, disclose personal data to third-party payment processors and third parties who perform services on behalf of the Company. The Company will assure that the third-party payment processors and third parties who perform services on behalf of the Company have an adequate level of protection of personal data that is consistent with this Privacy Policy.

Legal ground: contract.

2.5. Newsletters

If you sign up for our newsletter by using the “Sign up” functionality available on the Website, the Company will collect your email address for direct marketing purposes. If you would unsubscribe from receiving any future direct marketing material, please use the “unsubscribe” link contained in any newsletter sent by the Company to you. We will respond to your unsubscribe request within a reasonable period of time but no later than two weeks.

Legal ground: consent.

2.6. Device Information

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

Legal ground: legitimate interests.

2.7. Cookies

– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org

– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

– “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Legal grounds: legitimate interests and consent.

2.8. Non-Personal Data

The Company may collect non-Personal Data, such as browser types, operating systems, and the URL addresses of websites clicked to and from the Website in order to analyze what kind of users visit the Website, how they find it, how long they stay, from which other websites they come to the Website, what pages they look at, to which other websites they go from the Website.

Legal grounds: legitimate interests.

Please note that the Company complies with data minimization principles. We collect and process only a minimal amount of information that is necessary for performing the operations requested by you. The company does not attempt to collect any Personal Data from you which is not strictly necessary for performing the requested operations.

3. How we use your personal data

3.1. We use your personal data:

– for your registration;

– for providing our services or authorized services of the third parties;

– for communicating with you;

– for using your data with the purposes for which the data is provided;

– for customizing the Website’s content based on your location;

– for sending you notifications about updates of the Website;

– for auditing and security purposes;

– for the compliance with applicable laws;

– for assisting law enforcement bodies as required by law;

– when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. Information about promotions and/or events that may be of interest to you;

– we use the device information to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Website (for example, by generating analytics about how our customers browse and interact with the Website, and to assess the success of our marketing and advertising campaigns);

– your device information is helping us to give you the best recommendation for products that you are interested in using technologies;

– in case the Company is being sold partly or fully, the Company may also provide your personal data to a purchaser or successor entity.

4. Security

4.1 We have security and organizational measures and procedures to secure the data collected and stored. You acknowledge that no data transmission is guaranteed to be 100% secure and there may be risks. You are responsible for your login information and password. You shall keep them confidential. In case if your privacy has been breached, please contact us immediately.

4.2. We have necessary organizational and technical measures to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of your personal data.

4.3. You are responsible for keeping your login details in a private and secure manner.

5. Your rights

5.1. You can exercise the following rights by contacting us.

5.2. You have the right to access information about you, especially:

– the categories of data;

– the purposes of data processing;

– third parties to whom the data disclosed;

– how long the data will be retained and the criteria used to determine that period;

– other rights regarding the use of your data.

5.3. You have the right to make us correct any inaccurate personal data about you.

5.4. You can object to using your personal data for profiling you or making automated decisions about you. We may use your data to determine whether we should let you know the information that might be relevant to you.

5.5. You have the right to the data portability of your data to another service or website. We will give you a copy of your data in a readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you.

5.6. You have the right to be “forgotten”. You may ask erasing any personal data about you if it is no longer necessary for us to store the data for purposes of your use of the Website.

5.7. You have the right to lodge a complaint regarding the use of your data by us. You can address a complaint to your national regulator.

5.8. In the context of the right to access information, we shall provide you with the information within one month of your request unless there is a justified requirement to provide such information faster. This term may be extended according to the applicable law.

6. Location of the processing of personal data and third-party service providers

6.1. The personal data is collected and processed by our companies incorporated in the USA and Estonia.

6.2. The Website contains links to third-party sites. The Privacy Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their sites, features or policies. Please read their privacy policies before you submit any data to them.

6.3. There are the following third parties:

– camp organizers;

– email service providers to notify you and for direct marketing purposes;

– services for operating processes;

– payment services processors;

– website analytics companies to analyze data and improve our services and the Website;

– social media companies to promote and be present in social media.

7. Data retention

7.1. We store personal data as long as we need it and the retention practice depends on the type of data we collect, regulatory burden, and how we use the personal data. The retention period is based on criteria that include legally mandated retention periods, pending or potential litigation, intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving.

8. Links

8.1 The Website may contain links to other websites. The Company is not responsible for the privacy practices of those websites.

9. Amendment of this Privacy Policy

9.1. We may update the Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

10. California privacy

10.1. The California Consumer Privacy Act (“CCPA”) provides Californian residents with specific rights regarding their personal data. When the CCPA is applicable, you may request to disclose some data to you about our collection and use of your personal data over the past 12 (twelve) months. You may ask us to delete personal data collected from you unless there are exceptions. If we sell personal data, you may opt-out of that sale.

10.2. We may not discriminate against you for exercising a CCPA right and if you choose to enforce applicable CCPA rights, we shall not charge you different prices or provide you a different quality of the services.

11. Contact Us

11.1. For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at contact@bjjcampfinder.com or by mail using the details provided below:

Pemp Inc

[Re: Privacy]

19C Trolley Square

Wilmington, DE 19806

Privacy Statement

Last modified: 11 August 2020

We take your privacy very seriously and treats all your personal information with great care.

1. Introduction Who we are

1.1 Pemp Inc. having a principal place of business at 19C Trolley Square, DE 19806 United States of America (hereinafter, referred to as the “Company”, “we”, or “us”) collects from the individual user (hereinafter, referred to as “you” or “your”) certain personal data through the website https://bjjcampfinder.enev.me  (hereinafter, referred to as the “Website”).

1.2 This Privacy Policy contains Company’s policies and procedures governing the processing of personal data through the Website.

1.3 The Website enables you to find, compare and book Brazilian Jiu Jitsu vacations anywhere in the world.

2. Personal information we collect and why we collect it

2.1 Booking information

In order to sign of any of the listed camps in the Website you are required to enter certain information about yourself. The following information is obligatory and visible to 3rd Parties as Camp Organizers:
– First and Last Name;
– Email Address;
– Phone number;

2.2 Content

By using the Website in order to write a review you can make certain information available about yourself, such as your name, photo, place of residence, travel experience and other “about you-information” (“Content”). This information could include personal data. Once the Content is submitted, this is visible for other Users and Organizers on the Website.

2.3 Payment

The Company may, for the payment purposes, disclose personal data to the Third Party Payment Processors and third parties who perform services on behalf of the Company. The Company will assure that the Third Party Payment Processors and third parties who perform services on behalf of the Company have an adequate level of protection of personal data that is consistent with this Privacy Policy.

2.4 Newsletter

If you sign up for our newsletter by using the “Sign up for newsletter” functionality available on the Website, the Company will collect your email address for direct marketing purposes. If you would unsubscribe from receiving any future direct marketing material, please use the “unsubscribe” link contained in any newsletter sent by the Company to you. We will respond to your unsubscribe request within a reasonable period of time but no later than two weeks.

2.5  We collect Device Information using the following technologies:

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

2.6 Cookies

– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Please note that the Company complies with data minimization principles. We collect and process only minimal amount of information that is necessary for performing the operations requested by you. The company does not attempt to collect any personal information from you which is not strictly necessary for performing the requested operations.

3. How Do we use your Personal Information

– Communicate with you;
– Providing it to Organizers
– Use your data with the purposes for which the data is provided;
– Customizing the Website’s content based on your location;
– Sending you notifications about updates of the Website;
– Audit and security purposes; and assisting law enforcement bodies as requested by law.
– When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. Information about promotions and/or events that may be of interest to you.
– We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
– Your device information is helping us to give you best recommendation for products that you are interested in using technologies. For example this technologies include but are not limited to Facebook advertising, Messenger, Google Ads.
– In case the Company is being sold partly or fully, the Company may also provide your personal data to a purchaser or successor entity.

4. Non Personal Information collected by us.

4.1 The Company may collect non-personal data, such as browser types, operating systems, and the URL addresses of websites clicked to and from the Website.

4.2 The Company collects the non-personal data mentioned in this Section 4.1 in order to analyze what kind of users visit the Website, how they find it, how long they stay, from which other websites they come to the Website, what pages they look at, to which other websites they go from the Website.

5. Third Party Access to Personal Data

5.1 We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our users use the Site — you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

5.2 The personal data provided by you for signing up for our newsletter will be used by MailChimp, which is a trading name of Rocket Science Group, LLC, to provide you with the requested newsletter. If you would like to read MailChimp’s privacy policy, please visit https://mailchimp.com/legal/privacy.

5.3 The Company may, for the purposes specified in Section 5 of this Privacy Policy, disclose personal data to the Third Party Payment Processors and third parties who perform services on behalf of the Company. The Company will assure that the Third Party Payment Processors and third parties who perform services on behalf of the Company have an adequate level of protection of personal data that is consistent with this Privacy Policy.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information, Account and Order Information.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

6. Behavioral Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:
– Facebook: https://www.facebook.com/settings/?tab=ads
– Google: https://www.google.com/settings/ads/anonymous
– Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
– Pinterest: https://help.pinterest.com/en/articles/personalization-and-data

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

7. Protection of your personal data

7.1 The Company employs information security tools to protect personal data collected and processed through the Website. Such information security tools include, but not limited to, secured networks and encryption.

7.2 However, please note that, due to the inherent risks of using the Internet, we cannot be liable for any destruction, loss, leakage, and falsification of personal data caused by circumstances beyond our reasonable control.

7.3 We will put reasonable efforts to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of your personal data

7.4 You are solely responsible for keeping your login details in a private and secure manner.

8. Your rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example send you information for the camp on our website), or otherwise to pursue our legitimate business interests listed above in section 3. Additionally, please note that your information will be transferred outside of Europe, including to the United States.

9. Accessing and correcting your personal data

9.1 You can update, access, modify, and delete your personal data at any time. In order to do so, please adjust your profile on the Website or send an email to the following email address: contact@bjjcampfinder.com. The Company will answer your request within a reasonable time frame but no later than two weeks.

10. Data Retention

10.1 When you register through the Site, we will maintain your Account Information for our records unless and until you ask us to delete this information.

11. Your concent

11.1 By using the Website, you are consenting to our processing of your personal data as set forth in this Privacy Policy. The term “processing” includes collecting, storing, deleting, using, and disclosing personal data.

12. Links

12.1 The Website may contain links to other websites. The Company is not responsible for the privacy practices of those websites.

13. Amendment of this Privacy Policy

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. .

14. Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at contact@bjjcampfinder.com or by mail using the details provided below:

Pemp Inc
[Re: Privacy Compliance Officer]
19C Trolley Square
Wilmington, DE 19806

15. Last Amendment

15.1 You can submit a complaint about the way in which your privacy has been handled by using the contact details indicated in Section 14 of this Privacy Policy. After you submit such a complaint, we will send you an email within 5 business days confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable time frame.