Effective 2026-04-27
Privacy Policy
MatFlow Ltd ("MatFlow", "we") describes here how we handle personal data on behalf of gyms (our customers) and on behalf of those gyms' members.
1. Roles
- For your gym subscription: MatFlow is the data controller of your owner/staff account details (name, email, role).
- For member data: MatFlow is a data processor; the gym is the controller. We process member data on the gym's instructions.
2. What we store
- Member name, email, phone, optional date of birth, optional medical/emergency contact info
- Membership type, account type (adult/junior/kids), and waiver acceptance snapshot
- Stripe customer ID, subscription ID, and payment status (no card numbers — Stripe holds those)
- Attendance and class records
- Audit logs of sensitive operations (timestamp, IP, user agent)
We never store card numbers, CVVs, or full PANs. Stripe collects payment data directly via Stripe-hosted UI; MatFlow only receives a Stripe customer/subscription ID.
3. Lawful basis (UK GDPR)
- Contract — to provide the service the gym subscribed to
- Legitimate interest — security, fraud prevention, audit logging
- Explicit consent — for medical conditions, emergency contacts, and waiver storage
4. Sub-processors
We use third-party services as sub-processors. The current list is at /legal/subprocessors. Material changes are announced at least 30 days in advance.
5. Retention
- Active member data — for as long as the gym remains a customer
- Signed waivers — six years after the member leaves (UK limitation period)
- Audit logs — twelve months
- Backups — purged within 35 days of the live record being deleted
6. Your rights
Members of a gym should contact their gym for access, correction, deletion, or portability requests in the first instance. The gym (as data controller) responds, with MatFlow's assistance where needed. You may also email privacy@matflow.io.
UK members have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk.
7. International transfers
MatFlow uses Vercel, Neon, and Resend. Where data leaves the UK/EEA, transfers are protected by the UK IDTA or the EU Standard Contractual Clauses with applicable supplementary measures.
8. Security
We use TLS for all transport, encrypt OAuth tokens at rest with AES-256-GCM, hash passwords with bcrypt, and maintain audit logs of sensitive operations. Card data never reaches MatFlow servers — Stripe handles it.
9. Contact
Privacy questions: privacy@matflow.io.