Privacy Policy

1. Purpose

Entropy Jiu Jitsu LLC respects the privacy of its members, parents, guardians, visitors, staff applicants, and website, app, or platform users. This Privacy Policy explains how personal data is collected, used, stored, shared, and protected when you interact with Entropy, including how Entropy may generate commercial value from data in the limited, consent-based ways described in sections 10 and 11.

This policy is intended to operate in alignment with applicable UAE data protection requirements, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and its implementing regulations.

2. Data Controller

Entropy Jiu Jitsu LLC, 14 D67, Al Quoz Industrial Area 1, Warehouse 05, Dubai, United Arab Emirates, is the data controller for the purposes of this policy unless another party is expressly identified at the point of collection.

Contact for privacy matters: info@entropyjiujitsu.com · +971 4 323 8902

3. Categories of Personal Data We May Collect

Depending on the relationship with the data subject, Entropy may collect:

• full name, nationality where reasonably required, date of birth, gender where relevant to service allocation, and parent or guardian details for minors;
• phone number, email address, emergency contact details, general area of residence, and communication preferences;
• attendance records, booking history, membership data, program enrolment, and customer support communications;
• payment and transaction records necessary to complete or evidence a purchase or contractual relationship;
• identity information where reasonably required for verification, safeguarding, compliance, or dispute handling;
• CCTV footage or still imagery recorded on-site for safety, security, incident review, or facility management purposes;
• injury information, medical restrictions, or health-related documents voluntarily submitted or reasonably required for safe participation or cancellation assessment;
• photographs or videos taken during academy activities where permitted by law, contract, legitimate interest, or applicable consent;
• device, browser, and usage information collected through cookies and similar technologies on the Entropy website and member app, as described in section 18;
• your marketing and Commercial Partner Programme preferences, and a record of when and how you gave or withdrew consent.

4. How We Collect Personal Data

Entropy may collect personal data directly from the individual, from a parent or legal guardian, through membership forms and waivers, through our booking, CRM, and member app systems, through website and lead forms, through cookies and similar technologies, through email or WhatsApp communications, through payment processors, through CCTV systems, and through official or medical documents submitted to support a request.

5. Purposes of Processing

Entropy may process personal data for the following purposes:

• to create and manage memberships, bookings, events, and private sessions;
• to process payments, issue invoices, and maintain business and accounting records;
• to deliver classes, support academy operations, and communicate service updates;
• to maintain health, safety, safeguarding, and incident-response procedures;
• to assess cancellation, refund, freeze, complaint, and dispute requests;
• to comply with legal, regulatory, tax, insurance, and audit obligations;
• to improve service quality, operations, member experience, and internal reporting;
• to send marketing communications where permitted and, where required, based on consent;
• to present members with products, services, discounts, and events from Entropy's commercial partners, where the member has opted in;
• to monetize Entropy's data assets in the limited ways set out in sections 10 and 11, namely through partner offers sent by Entropy, aggregated and anonymised insights, and, with separate opt-in consent only, the Commercial Partner Programme.

6. Lawful Basis · Permitted Grounds

Entropy processes personal data only where there is an appropriate lawful or permitted basis under applicable UAE law, including where processing is necessary to perform a contract, comply with a legal obligation, protect health and safety, support legitimate and proportionate business operations, or rely on the individual's consent where consent is required.

Any sharing of identifiable personal data with commercial partners for their own marketing relies exclusively on your separate, specific, and freely given consent, which you may withdraw at any time.

7. Health Data and Medical Documents

Because martial arts training is a physical activity, Entropy may need limited health-related information that is relevant to training safety, emergency response, injury management, or membership administration.

Where health-related information is collected, Entropy will seek to limit collection to what is reasonably necessary, restrict access internally, and treat such information with heightened confidentiality. Health-related information is never used for commercial purposes and is never shared with commercial partners.

If a medical suspension, freeze, or cancellation request is made, Entropy may request a medical report or certificate issued by a UAE-licensed healthcare provider and, where applicable, attested or verifiable through the relevant UAE health authority.

8. Children's Data

Where a child is enrolled, personal data may be processed through the child's parent or legal guardian for registration, attendance, welfare, emergency contact, safeguarding, and service delivery purposes.

Parents or legal guardians are responsible for ensuring that the information they provide is accurate and that they are authorized to provide it.

Personal data relating to any member under 18 is never used for commercial purposes and is never shared with commercial partners. A parent or guardian's marketing or Commercial Partner Programme consent applies to the parent or guardian's own contact details only.

9. Marketing Communications

Entropy may send updates, offers, event notices, academy announcements, and service-related messages through email, SMS, WhatsApp, in-app notifications, or social platforms where permitted by law.

With your marketing consent, these messages may include offers from Entropy's commercial partners, for example sportswear and equipment brands, nutrition and wellness providers, physiotherapy and recovery clinics, insurers, and local hospitality or retail businesses. In that case Entropy sends the message and the partner does not receive your contact details, unless you have separately opted in under section 11. Entropy may be paid by partners for featuring their offers.

You may opt out of marketing communications at any time by using the unsubscribe link, replying STOP, adjusting your preferences in the member app, or emailing info@entropyjiujitsu.com. Operational, safety, billing, legal, or service notices are not marketing messages where they are necessary to administer the membership or protect legitimate operational interests.

10. Sharing of Personal Data

Entropy shares personal data in the following circumstances only:

• Service providers acting on Entropy's instructions, including payment processors, CRM, booking, and membership platforms, website and app hosting, cloud and software providers, and communication tools. These providers may process data only for Entropy's purposes and under contractual confidentiality and security obligations.
• Professional and regulatory recipients, including professional advisers, insurers, auditors, medical or emergency responders in urgent situations, and legal or regulatory authorities where required or permitted by law.
• Commercial partners, but only where you have given the separate opt-in consent described in section 11, and only the categories of data described there.
• Business transfers. If Entropy sells, merges, or restructures all or part of its business, personal data may be transferred to the successor, who will be bound by this policy.

Entropy may also create and share aggregated or anonymised information, for example attendance trends, class demand, or demographic bands, with sponsors, partners, and other third parties for commercial purposes, including for a fee. This information is prepared so that it cannot reasonably be used to identify any individual.

11. Commercial Partner Programme

Entropy works with selected commercial partners whose products or services may interest its members. If you opt in to the Commercial Partner Programme, Entropy may share the following with partners in the categories you have agreed to: your name, email address, mobile number, the Entropy program you are enrolled in (for example Adults, Ladies Only, or Corporate) and, where relevant, your general area of residence. Partners may use this information to contact you with offers and to tailor those offers to you. Entropy may receive a fee, commission, or other benefit from partners in connection with the Programme.

Opting in is voluntary and is not a condition of membership, pricing, or access to any class. You can opt in or out at any time through the member app, your account preferences, or by emailing info@entropyjiujitsu.com. Withdrawal takes effect within 10 business days, after which Entropy will instruct partners to stop using your data. Withdrawal does not affect the lawfulness of sharing that took place beforehand.

Every partner that receives personal data must agree in writing to use it only for the purpose you consented to, not to sell or pass it on, to keep it secure to a standard consistent with UAE law, and to delete it when Entropy asks. Entropy maintains a current list of partner categories at entropyjiujitsu.com/partners and will update it when categories are added.

No health-related information, medical documents, attendance records, payment details, CCTV or photographic imagery, or any data relating to a member under 18 is ever shared under the Programme.

12. International Transfers

Where service providers or commercial partners store or process personal data outside the UAE, Entropy will take reasonable steps to ensure appropriate protections are applied in light of the nature of the data, the destination, and the applicable legal requirements, and will rely on your consent where the law requires it.

13. Data Retention

Entropy retains personal data only for as long as reasonably necessary for the purpose for which it was collected, including membership administration, safeguarding, accounting, incident review, complaint handling, dispute management, and compliance with legal, regulatory, or audit obligations. Records of consent are kept for as long as the consent is relied on and for a reasonable period afterwards as evidence.

When personal data is no longer required, Entropy will delete, anonymize, or securely archive it as appropriate.

14. Security Measures

Entropy implements reasonable technical, organizational, and administrative measures designed to protect personal data from unauthorized access, misuse, alteration, disclosure, loss, or destruction.

While Entropy seeks to maintain appropriate safeguards, no electronic system or transmission method can be guaranteed to be completely secure.

15. Data Subject Rights

Subject to applicable law and any lawful exceptions, individuals may request access to their personal data, correction of inaccurate data, deletion or erasure in applicable cases, restriction of processing in applicable cases, objection to certain processing including direct marketing, and withdrawal of consent where processing relies on consent.

You may withdraw your Commercial Partner Programme consent and your marketing consent independently of each other at any time, without affecting your membership.

Requests may be submitted to info@entropyjiujitsu.com. Entropy may require identity verification before acting on a request.

16. CCTV and On-Site Monitoring

Entropy may use CCTV in parts of its premises for safety, security, incident review, and facility protection purposes. CCTV will not be used in areas where privacy is reasonably expected.

17. Third-Party Platforms

If you interact with Entropy through Instagram, WhatsApp, Meta lead forms, payment gateways, booking systems, or other third-party tools, your data may also be processed under those providers' own terms and privacy policies. Entropy is not responsible for third-party privacy practices outside its direct control.

18. Cookies and Website Tools

Entropy's website and member app use cookies and similar technologies. Strictly necessary cookies run the site, the cart, and your login and cannot be switched off. With your consent, Entropy also uses analytics cookies to understand how the site is used, functional cookies to remember your preferences, and marketing cookies, including those set by advertising platforms such as Meta and Google, to measure campaigns and show relevant advertising on and off the site.

When you first visit, a cookie banner lets you accept all, reject all non-essential cookies, or choose by category. You can change your choice at any time through the "Manage Cookies" link in the website footer. Rejecting non-essential cookies does not affect your ability to use the site or book a class. Entropy's current cookie list, including the identity of each third party, is available at entropyjiujitsu.com/cookies.

19. Policy Updates

Entropy may update this Privacy Policy from time to time to reflect changes in law, guidance, systems, or business practices. Material changes, including any change to how personal data may be shared or used commercially, will be notified to members by email or in-app notice at least 30 days before they take effect. The latest version shall apply from its stated effective date.

This version (2.0) takes effect on 19 November 2026. Until that date, the previous version continues to apply, and no personal data will be shared with commercial partners before then.

20. Governing Law and Contact

This Privacy Policy shall be governed by the laws of the United Arab Emirates and the applicable laws and regulations of the Emirate of Dubai.

For privacy questions or requests, please contact Entropy Jiu Jitsu LLC at info@entropyjiujitsu.com or +971 4 323 8902.