Privacy policy
Huppa B.V., a private limited liability company with its registered office and offices at Lauriergracht 39 in Amsterdam, the Netherlands, registered in the Trade Register of the Chamber of Commerce under number 92363067 (Huppa, we, us, or our) developed and commercializes the Huppa operating system (hereinafter Huppa OS) and makes it available to (i) Consumer Users, being consumers who use the Huppa OS to book sports classes, activities, or other services offered by Customers of Huppa; and (ii) Professional Users, being sports instructors, trainers, or other service providers (including independent contractors) of gyms or studios that use Huppa OS (Customers). Professional Users use Huppa OS to offer their services through the business of Customers. (Consumer User and Professional User together referred to as User or Users).
In this document, the terms "you" or "your" refers to the Users (the Consumer User or the Professional User, as apparent from the context).
1. INTRODUCTION
Through this privacy policy, we aim to be transparent about what personal data Huppa collects from Users, why Huppa collects this personal data, and what Huppa does with this collected personal data. We handle the personal data of Users with care and always comply with applicable laws and regulations as described hereafter.
2. ROLE DISTRIBUTION UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
A "controller", as defined in Article 4(7) of the GDPR, determines how and why personal data is processed.
With regard to Users, Huppa processes their personal data as a service for its Customers in the context of their subscription to the Huppa OS. In this context, Huppa's Customer is considered the "controller" as defined in Article 4(7) of the GDPR. Huppa is a "processor" in this context, as defined in Article 4(8) of the GDPR. For more information about the processing of personal data by Huppa’s Customer we refer you to the privacy policy of the relevant Customer.
3. LEGAL BASIS
Huppa processes personal data of Users based on the following principles included in the GDPR:
1. consent;
2. performance of a contract;
3. legal obligation; and
4. legitimate interest of Huppa or a third party.
By legitimate interests, we mean, among other things: advertising, marketing, security, auditing, fraud detection, (crime) prevention, (market) research and analysis and improvement of our services, internal management, legal matters and business administration.
4. PERSONAL DATA PROCESSED BY HUPPA FROM USERS: PURPOSES AND LEGAL BASIS
When using the Huppa OS, Huppa processes the personal data of Users for the purposes and on the basis described below. The basis applicable to a specific processing operation is indicated below.
Creating a user account: in order to create an account that gives Users access to the Huppa OS, the person concerned must provide their contact details, namely: the company name of the gym/studio/service provider, first name, last name, email address and password. Legal basis 2 applies.
Transactional data (applicable for Consumer Users): details of classes booked and attended, payments from your account and other details of products and services you have booked and purchased. Legal basis 2 applies.
Transactional data (applicable for Professional Users): details of classes planned, taught and/or hours worked, account and other details of products and services provided to Professional Users. Legal basis 2 applies.
Payment data: For the processing of payments related to bookings and purchases made through Huppa OS, Huppa uses the services of third-party payment service provider Mollie B.V. Direct financial payment information such as credit card numbers, bank account details and other financial sensitive payment data are collected and processed directly by Mollie and are not stored or processed by Huppa. Huppa only processes payment-related personal data necessary for transaction management, including transaction identifiers, payment status and amounts paid, to facilitate the booking process and provide transaction history to Users. Huppa does not have access to your complete payment card details or bank account information. For more information about how Mollie processes your payment data, please refer to Mollie's privacy policy at https://www.mollie.com/legal/privacy. Legal basis 2 applies.
Technical data: We process your IP address, login data, traffic data, browser type and version, phone type, version, time zone settings and location, operating system and platform and other information about how you accessed the Huppa OS. This data is processed to ensure the security and proper functioning of the Huppa OS, to optimize system performance, to provide technical support, to prevent fraud and unauthorized access and to comply with legal obligations. Legal basis 2 and 4 apply.
Data aggregation: in order to minimize the processing of personal data, Huppa uses data aggregation (including merging or encrypting personal data to create pseudonymized personal data). Huppa may also anonymize personal data, meaning the data is processed in such a way that it can no longer be attributed to a specific natural person as described in the GDPR. Once personal data has been fully anonymized and is no longer traceable to natural persons, the GDPR no longer applies to such fully anonymized data. Legal basis 4 applies.
Compliance with (local) legislation: to comply with applicable legislation, Huppa may be required to process your personal data for purposes other than those set out in this privacy policy, for example for law enforcement or in the event of a court order. Legal basis 3 applies.
Customer service: Huppa may process Users' contact details to provide customer service. In this context, Huppa may, for example, collect (written) requests received and the related responses, together with other contact details (customer company name, first name, last name, and email address of the Consumer User) and any other information you may provide. This enables Huppa to respond to questions more effectively. Depending on the processing, legal basis 1 or 4 applies.
Testing and analysis for service provision: Huppa uses your usage data of the Huppa OS in pseudonymized form to detect and remedy errors and malfunctions in the current Huppa OS services. Legal basis 2 applies.
Service improvement: Huppa may use Users' personal data in pseudonymized form to improve existing features of the Huppa OS. Legal basis 4 applies.
New product development: For the development of new products or services, Huppa will only use Users' personal data with their explicit prior consent. Legal basis 1 applies.
Marketing: to the extent permitted by applicable law, Huppa may use Professional Users' contact details for marketing communications, such as newsletters. Professional Users can unsubscribe from these at any time. The newsletter may also contain information and offers from other parties. Each newsletter contains a link that allows the Professional User to unsubscribe from the newsletter. The newsletter subscriber database will not be provided to third parties unless the Professional User has given their explicit consent. Depending on the processing, legal basis 1 or 4 applies.
Other data: in addition to the specifically mentioned categories of personal data as included in this privacy policy, we may also process other personal data that a Consumer User provides to us in the context of using the Huppa OS. This includes all personal data that Users share with us, but which does not fall under any of the other specific categories. Depending on the processing, legal basis 1 or 4 applies.
5. RETENTION PERIOD OF PERSONAL DATA
Huppa does not retain personal data longer than is permitted under applicable law or when Huppa believes it is necessary and appropriate to retain personal data for a longer period.
In any case, the data required to create an account (as described above) will be retained for as long as a User has an active account. After deleting the user account, the account data of a User will be retained for a maximum period of 12 months.
6. PROVISION OF PERSONAL DATA TO THIRD PARTIES
In the following cases, Huppa may share your personal data with third parties.
External service providers: We may share your personal data for the purposes set out in this privacy policy with external service providers if this is necessary for the provision of Huppa OS, such as hosting, data analysis and storage, information technology and related infrastructure, customer service, diagnostics, email delivery, auditing, and marketing. We only share your personal data with external service providers that offer sufficient guarantees for the protection of your personal data. Depending on the processing, legal basis 2 or 4 applies.
Competent authorities: We disclose personal data to law enforcement authorities and other government agencies to the extent required by law or strictly necessary for the prevention, detection, or prosecution of criminal offenses and fraud. Legal basis 4 applies.
Transfer: We may transfer personal data to third parties in the event that our organization is subject to a merger, acquisition, reorganization, sale of business units, or bankruptcy. We will ask for your prior consent if required by applicable law. Depending on the processing, legal basis 1 or 4 applies.
If the above organizations are considered processors under European privacy legislation, we will enter into a processing agreement with them. Your personal data will then only be processed on our instructions and under our responsibility.
7. TRANSFER OF PERSONAL DATA ABROAD
Huppa OS is managed and operated from the Netherlands. If personal data is nevertheless provided to a third party abroad, this will only be done to a third party in a country that, according to the European Commission, offers an adequate level of protection for personal data. If this adequate level of protection is lacking, we will ensure that the legally required safeguards are provided, such as the conclusion of an EU model contract.
At the time of drafting this privacy policy, personal data is not transferred abroad.
8. USE OF COOKIES
Huppa uses cookies on Huppa OS. By clicking "agree" on the cookie notification or by continuing to use Huppa OS you consent to the placement of cookies. A cookie is a simple small file that a website stores on your hard drive via your browser. A cookie contains stored information. Various types of cookies may be used per visit. Below you will find more information about the cookies used and for which purposes.
What types of cookies are used on the Website and for what purpose. Huppa OS uses the different types of cookies listed below for the purposes listed below:
Strictly necessary cookies: for example authentication or session cookies that store information on whether you are allowed to login and can remain logged in.
Analytical cookies: these are anonymous cookies that enable Huppa to improve Huppa OS. These cookies collect information about how Users use Huppa OS, such as information about the most visited pages or the number of error messages displayed. The information collected by these cookies may not be used for marketing purposes and is not passed on to third parties.
Functional cookies: these are anonymous cookies that ensure that Huppa OS functions correctly. These cookies are used, for example, to store browser settings so that Huppa OS can be viewed optimally, or to ensure that Huppa OS remains accessible (load balancing), but also cookies that prevent other cookies from being placed (no-follow).
Specific overview of cookies used: For a detailed overview of all cookies used by the Huppa website (https://huppa.app/), please visit [COOKIE OVERVIEW LINK]. For information about cookies and trackers used within Huppa OS, please refer to the cookie and privacy settings within the App.
Adjusting cookie settings or deleting cookies: If you do not want Huppa to place cookies on your (mobile) device, you can refuse the use of cookies via your browser settings or options. You must adjust your settings separately for each browser and each (mobile) device. Please note: after adjusting the cookie settings, some parts of the Huppa OS or the Tool may no longer be able to be used (correctly). If Huppa has placed cookies, you can also delete them. How to do this varies per browser. If necessary, consult your browser's help function. More information about cookies can be found on the website of the Consumers' Association.
If you encounter cookies on Huppa OS that we have not mentioned above, we kindly ask you to report this to us.
9. SECURITY
Huppa takes all necessary measures to protect your personal data. To this end, Huppa uses technical and organizational security measures to protect personal data against manipulation, loss, destruction, and unauthorized access.
More specifically, Huppa has taken the following measures, among others, to protect your personal data.
Only our authorized employees who need access to personal data can view and process your data. All our employees are bound by confidentiality and are not allowed to disclose personal data unlawfully or unnecessarily.
If the explicit processing of personal data is not necessary, but data must be linked to an identity, we will use anonymous identifiers within our system. These identifiers do not allow any direct inference of the actual and concrete personal data.
The link between personal data and anonymous identifiers within Huppa OS is protected and regulated by means of encryption of this data, strict restriction of access to decryption, and logging and monitoring of access data.
Our security measures are continuously improved in line with technological developments.
10. YOUR RIGHTS
You have the right to access, correct, or delete your personal data at any time. To do so, please contact us using the contact details below. Finally, we would like to point out that, based on European privacy legislation, you also have the following rights:
to receive an explanation of what personal data we hold about you and what we do with it;
access the exact personal data we hold about you;
to have incorrect data corrected;
to have outdated personal data deleted;
withdraw consent for the processing of your personal data; and
object to a specific use of your personal data.
If, despite our efforts to ensure the accuracy of your personal data, inaccuracies are stored, we will correct or delete them at your request.
Huppa may in some cases refer your request to the Customer.
When you request deletion of your personal data, Huppa will assess your request as follows: (i) personal data that Huppa is legally required to retain, such as financial records and invoices, will be retained for the mandatory retention period of 7 years as required by Dutch tax law. This data cannot be deleted or anonymized during this period. (ii) for other personal data, where anonymization serves legitimate business interests such as maintaining historical records, transactional data, and analytics, Huppa will fully anonymize your data rather than delete it entirely. Once anonymized, the data can no longer be attributed to you as an individual and is no longer considered personal data under the GDPR. (iii) If you object to anonymization and request complete deletion, and no legal obligation or overriding legitimate interest applies, Huppa will proceed with full deletion. Please note that Huppa may refer certain deletion requests to the relevant Customer, as they act as the controller for certain personal data processing activities.
11. COMPLAINTS
Huppa is happy to help you if you have a complaint about the processing of your personal data. In the event of a complaint, please contact us using the contact details below. Under European privacy legislation, you also have the right to lodge a complaint directly with the Dutch Data Protection Authority about the way in which we process your personal data.
12. CHANGES
Huppa reserves the right to change this privacy policy. The most current version of this privacy policy can be found on the Huppa website. We recommend that you check regularly to see if an updated version is available.
13. CONTACT
If you have any questions about this privacy policy and/or the processing of your personal data by Huppa, please contact us at support@huppa.app.
14. VERSION
This privacy policy was last amended on December 16, 2025.
View of Terms of Use here.