Privacy Policy

Last updated: 28/05/2025

Your privacy is important to us.

In this Privacy Policy, we explain what personal data we collect from our users and how we use it.

We encourage you to read these terms carefully before providing your personal data on this website.

This website respects and protects users’ personal data. As a user, you should know that your rights are guaranteed.
We have taken great care to create a secure and trustworthy space, and we want to share our principles regarding your privacy:

· We never request personal information unless it is truly necessary to provide the services you require.

· We never share personal information about our users with anyone, except to comply with the law or with your explicit permission.

· We never use your personal data for purposes other than those stated in this Privacy Policy.

Please note that this Privacy Policy may change due to legal requirements or self-regulation, so we advise users to visit it periodically.

It applies whenever users fill out any contact forms that collect personal data.

To process user data, we implement all technical and organizational security measures as established by current regulations.

Principles We Will Apply to Your Personal Information
When processing your personal data, we will apply the following principles that comply with the requirements of the Indonesian law (UU PDP) and, where applicable, the European Union General Data Protection Regulation (GDPR):

· Principle of lawfulness, fairness, and transparency: We will always require your consent for the processing of your personal data for one or more specific purposes, which we will inform you about beforehand with complete transparency.

· Principle of data minimization: We will only request data strictly necessary in relation to the purposes for which they were requested. The minimum possible.

· Principle of limitation of storage period: Data will be kept no longer than necessary for the purposes of processing. Depending on the purpose, we will inform you of the corresponding retention period. In the case of subscriptions, we will periodically review our lists and delete records that have been inactive for a considerable time.

· Principle of integrity and confidentiality: Your data will be processed in such a way as to guarantee adequate security of personal data and confidentiality. You should know that we take all necessary precautions to prevent unauthorized access or misuse of our users’ data by third parties.

Data Controller
In compliance with Indonesian legislation (UU PDP) and, where applicable, the European Union General Data Protection Regulation (GDPR), it is informed that the personal data collected through this website will be processed by:

Commercial name: Elite Surf Coaching
Legal entity: Elite Surf International PT
Address: 94GX+7QM, Canggu, Kuta Utara, Badung Regency, Bali, Indonesia
Contact email: info@elitesurfcoaching.com
Website: www.elitesurfcoaching.com
Jurisdiction: Indonesia

How Did We Obtain Your Data?
The personal data we process at Elite Surf Coaching come from:

· Contact form

· Newsletter subscription form

· Service request form

· Download form

What Are Your Rights When You Provide Us with Your Data?
Anyone has the right to obtain confirmation about whether Elite Surf Coaching is processing personal data concerning them or not.
Interested persons have the right to:

· Request access to personal data relating to them

· Request correction or deletion

· Request restriction of processing

· Object to processing

· Request data portability

Interested parties can access their personal data, as well as request correction of inaccurate data or, where appropriate, request deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected. Under certain circumstances, interested parties can request the restriction of the processing of their data, in which case we will only keep it for the exercise or defense of claims.
Under certain circumstances and for reasons related to their particular situation, interested parties may object to the processing of their data.

Elite Surf Coaching will stop processing the data, except for compelling legitimate reasons or the exercise or defense of possible claims.
As an interested party, you have the right to receive the personal data concerning you that you have provided us with, in a structured, commonly used, and machine-readable format, and to transmit it to another data controller when:

· The processing is based on consent

· The data have been provided by the data subject

· The processing is carried out by automated means

When exercising your right to data portability, you have the right to have the personal data transmitted directly from controller to controller where technically feasible.
Interested parties also have the right to effective judicial protection and to file a complaint with the supervisory authority.

For what purposes do we process your personal data?

When a user connects to this website, for example to comment on a post, send an email to the owner, subscribe to the newsletter, or make a purchase, they provide personal information for which Elite Surf Coaching is responsible.
This information may include personal data such as your IP address, name, physical address, email address, phone number, and other information. By providing this information, the user gives their consent for their information to be collected, used, managed, and stored by www.elitesurfcoaching.com only as described in this Privacy Policy.

At Elite Surf Coaching, there are different systems for capturing personal information, and we process the information provided by interested individuals for the following purposes depending on each capture system (forms):

· Contact form: We request the following personal data: Name, Email, Phone, to respond to the requests of users of our company. For example, we may use this data to respond to your inquiry and address any questions, complaints, comments, or concerns you may have regarding the information included on the website, the services provided through the website, the processing of your personal data, issues related to the legal texts included on the website, as well as any other inquiries you may have that are not subject to the terms of contracting.

· Newsletter subscription form: In this case, we request the following personal data: Name, Email, to manage the subscription list, send newsletters, promotions, and special offers provided by the user upon subscription. There are various forms on the website to activate the subscription.

· Service request form: We request the following personal data: Name, Email, Phone, to request any of the services that Elite Surf Coaching offers to its users. The collected information will allow us to process the requested service, possibly offline.

· Download form: On this website, different content can be downloaded periodically. In this case, we request the following personal data: Name, Email, to activate the subscription form. Your information will be used for the purposes indicated for subscribers.

We inform you that the data you provide through any of the means will be stored on servers located at:

. Google Analytics: A web analytics service provided by Google, Inc., a Delaware company with its principal office at 1600 Amphitheatre Parkway, Mountain View, California, CA 94043, USA (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help www.elitesurfcoaching.com analyze how users use the website. The information generated by the cookie about your use (including your IP address) will be directly transmitted to and stored by Google on servers in the United States.

· CDMON 10dencehispahard S.L (provider of Elite Surf Coaching), located in Spain C/ Girona 81-83 local 6 de Malgrat de Mar 08380, e-mail info@cdmon.com. Privacy Policy

· Brevo (provider of Elite Surf Coaching, SENDINBLUE — 17 rue de Salneuve, 75017, Paris, France.Intra-community VAT number: FR80498019298. Hosts: Kinsta Inc, 8605 Santa Monica Blvd #92581 West Hollywood, CA 90069 and Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723. Privacy Policy

There are other purposes for which we process your personal data:

· To ensure compliance with the terms of use and applicable law. This may include developing tools and algorithms that help this website guarantee the confidentiality of the personal data it collects.

· To support and improve the services offered by this website.

· Other non-identifying data is collected via some cookies downloaded to the user’s computer when browsing this website, as detailed in the cookie policy.

· To manage social media. Elite Surf Coaching may have a presence on social media platforms. The processing of data from people who follow the official social media pages of www.elitesurfcoaching.com will be governed by this section, as well as by the terms of use, privacy policies, and access regulations of each respective social network accepted previously by the user. We will process their data to properly manage their presence on the social network, informing them about Elite Surf Coaching’s activities, products, or services, as well as for any other purposes allowed by the social network’s policies.

Elite Surf Coaching does not sell, rent, or share personal data that can identify the user, nor will it do so in the future, with third parties without prior consent. However, in some cases, collaborations with other professionals may occur; in such cases, users’ consent will be requested, informing them about the collaborator’s identity and the purpose of the collaboration.

All data sharing will always be carried out with the strictest security standards. We may select and publish client testimonials on our Services, which may contain personally identifiable information such as their name and/or the city, state, or country where they live. We obtain their consent before publishing any testimonial with their name. If such content is published, it will be available to other users of the Services. If you want us to remove or delete your name or testimonial from our website, you can contact www.elitesurfcoaching.com through our contact page.

We may publish customer reviews on our website, which may include personally identifiable information such as your name and/or the city, state, or country where you live. By submitting your review, you are giving us permission to publish your opinion on our website or social media. If you publish such content, it will be available to other users of the Sites or Services. Its publication may also become public, and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you want us to remove your name, you can contact www.elitesurfcoaching.com via our contact form.

Legal basis for processing your data
The legal basis for processing your data is: consent.
To contact or comment on this website, consent to this privacy policy is required.
The prospective or commercial offer of products and services is based on the consent requested, without in any case the withdrawal of this consent conditioning the execution of the subscription contract.

Category of data
The categories of data processed are identifying data.
Special categories of protected data are not processed.

How long will we keep your data?
Personal data provided will be kept:

· As long as the commercial relationship is maintained.

· Until the data subject requests its deletion.

To whom will your data be disclosed?
Many tools we use to manage your data are provided by third parties.
To provide services strictly necessary for the development of the activity, www.elitesurfcoaching.com shares data with the following providers under their respective privacy conditions.

All third-party services offered are strictly necessary for the development of our services and have been selected according to compliance with the rights we preserve on this website.

The following companies will have access to the personal information necessary to perform their functions as data processors but may not use it for other purposes. Additionally, they must process personal information in accordance with this Privacy Policy and applicable data protection laws.

· CDMON 10dencehispahard S.L (provider of Elite Surf Coaching), located in Spain C/ Girona 81-83 local 6 de Malgrat de Mar 08380, e-mail info@cdmon.com. Privacy Policy

· Chat communication: We have several chat communication service providers:
• Zoom Video Communications, Inc., based in the USA. More information at: https://zoom.us/ (Zoom Video Communications, Inc.). Zoom Video Communications, Inc. processes data to provide chat communication services to Elite Surf Coaching.

Browsing
When browsing www.elitesurfcoaching.com, non-identifiable data may be collected, which can include IP addresses, approximate geographic location, a record of how the services and sites are used, and other data that cannot be used to identify the user. Non-identifiable data also includes information related to your browsing habits through third-party services. This website uses or may use the following third-party analytics services:
• Google Analytics
• Semrush
• Facebook Pixel
• Google Ads tracking tags

We use this information to analyze trends, manage the site, track users’ movements around the site, and to gather demographic information about our overall user base.

Data secrecy and security
www.elitesurfcoaching.com is committed to the use and processing of personal data included from users, respecting their confidentiality and using it only according to its intended purpose. We also comply with obligations to safeguard data and adopt all necessary measures to prevent alteration, loss, unauthorized processing, or access, in accordance with current data protection regulations.

This website includes an SSL certificate. This is a security protocol that ensures your data travels intact and securely — that is, the transmission of data between a server and a web user, and back, is fully encrypted.

www.elitesurfcoaching.com cannot guarantee the absolute invulnerability of the Internet network and therefore cannot guarantee protection against data breaches through fraudulent access by third parties.

Regarding the confidentiality of processing, Elite Surf Coaching will ensure that any person authorized by the company to process customer data (including staff, collaborators, and providers) will be under appropriate confidentiality obligations.

In the event of a security incident, once Elite Surf Coaching becomes aware of it, it shall notify the Client without undue delay and provide timely information related to the Security Incident as it becomes known or when reasonably requested by the Client.

Accuracy and truthfulness of data
As a user, you are solely responsible for the truthfulness and accuracy of the data you send to www.elitesurfcoaching.com, releasing Elite Surf Coaching from any related liability.
Users guarantee and are responsible, in any case, for the accuracy, currency, and authenticity of the personal data provided, and commit to keeping it duly updated. The user agrees to provide complete and correct information in the contact or subscription form.

Acceptance and consent
The user declares to have been informed about the conditions on personal data protection, accepting and consenting to the processing of their data by Elite Surf Coaching as described and for the purposes indicated in this privacy policy.

Revocability
The consent given, both for processing and for the transfer of the data of the interested parties, is revocable at any time by notifying Elite Surf Coaching according to the terms established in this Policy for the exercise of rights. This revocation shall not have retroactive effect.

Changes in the privacy policy
Elite Surf Coaching reserves the right to modify this policy to adapt it to legislative or jurisprudential changes, as well as industry practices. In such cases, Elite Surf Coaching will announce on this page the changes introduced with reasonable anticipation before their implementation.

Commercial emails
In accordance with the LSSICE (Spanish Law on Information Society Services and Electronic Commerce), www.elitesurfcoaching.com does not engage in SPAM practices and does not send commercial emails that have not been previously requested or authorized by the user. Consequently, on each form available on the website, the user has the possibility to give their express consent to receive the newsletter, independently of any commercial information specifically requested.

Pursuant to Law 34/2002 on Information Society Services and Electronic Commerce, www.elitesurfcoaching.com commits not to send commercial communications without properly identifying them.

Questions or inquiries about this policy or your rights
If you have any questions or comments about this policy, or if you have any concerns about how any personal information you have provided us may have been handled, you can contact us by postal mail or email at:
info@elitesurfcoaching.com