In accordance with Arts. 13–14 of GDPR 2016/679, Legislative Decree 196/2003 and Ministerial Decree 7 December 2006 no. 305

Note
In this document:
– “GDPR” refers to Regulation (EU) 2016/679;
– “Privacy Code” refers to Legislative Decree no. 196 of 30 June 2003, as amended;
– “D.M. 7/12/2006 n. 305” refers to the Regulation on the processing of sensitive and judicial data.

1. Data Controller
Bulwark s.s.d. a R.L. – Via Vittorio Veneto, 92B, 20091 Bresso (MI), Italy
Email: info@blwrk.fit | Website: www.blwrk.fit

2. Categories of Personal Data Collected
2.1 Identification and Contact Data
– First and last name, address, date and place of birth, tax code, identity document details
– Telephone number, email address

2.2 Sports Activity Data
– Registration details, membership records, fees, platform usage (e.g. Wodify)

2.3 Website Usage and Marketing Data
– Access logs, user preferences, newsletter consent

2.4 Health Data (Sensitive)
– Certificates of fitness for competitive and non-competitive sports

3. Mandatory Nature of Data Provision
– Providing personal data is optional but necessary for the purposes set out in sections 4.1 and 4.2: refusal will make it impossible to register or participate in activities.
– Refusal to provide the health data referred to in section 2.4 will prevent registration in the National Register of Amateur Sports Associations and Clubs (Registro Nazionale delle ASD/SSD).

4. Purposes and Legal Bases for Processing
4.1 Legal, Fiscal, Insurance and Statutory Obligations
– Compliance with laws, regulations, federation charters, CONI/ASI rules (art. 6(1)(c) GDPR).
– Membership management, fee collection, insurance policy administration.

4.2 Profiling and Promotional Communications (Only with Consent)
– Analysis to propose tailored courses or activities (art. 6(1)(a) GDPR).
– Sending newsletters and promotional materials, subject to prior consent.

5. Processing Methods
– By manual, IT and telematic means.
– Technical and organizational safeguards (TLS/SSL encryption, authentication controls, regular backups).

6. Data Retention
– Accounting/fiscal data: 10 years.
– Health data: duration of the membership relationship plus 10 years.
– Website usage data: up to 24 months.
– Marketing data: until consent is withdrawn.

7. Data Disclosure and Transfer
– Internal recipients: administrative staff, in-house legal and tax advisors.
– External recipients: CONI Servizi S.p.A. via ASI Lombardia; recognized sports federations; service providers (hosting, software, payment) including those outside the EU under standard contractual clauses.
– No dissemination to unspecified third parties.

8. Data Subject Rights
Right of access, rectification, erasure, restriction, objection, portability, and withdrawal of consent (arts. 15–22 GDPR).
To exercise these rights, send a request to info@blwrk.fit. We will respond within one month (extendable by two months). Complaints may be lodged with the Italian Data Protection Authority.

9. Cookies and Tracking Technologies
See our Cookie Policy: https://www.blwrk.fit/impostazioni-cookie

10. Security Measures
TLS/SSL encryption; access controls; periodic backups and disaster recovery.

11. Updates and Contacts
Any updates will be published with a new “Revision Date.”
For further information, contact info@blwrk.fit.

12. Revision Date
2 May 2025

In accordance with Arts. 13–14 of GDPR 2016/679, Legislative Decree 196/2003 and Ministerial Decree 7 December 2006 no. 305

Note
Glossary as above.

1. Purposes of Processing
– Internal documentation and historical archiving
– Promotion on the website and social media channels (Instagram, Facebook, etc.)
– Dissemination of initiatives and performances

2. Legal Basis
– Specific recordings of individuals: explicit consent (Art. 6(1)(a) GDPR).
– Panoramic and general overview recordings: legitimate interest (Art. 6(1)(f) GDPR, Art. 2-sexies Legislative Decree 196/2003, Recital 47 GDPR).

3. Processing Methods
– Collection of photographs and videos using digital equipment
– Storage on protected servers with periodic backups
– Publication on BULWARK’s online channels

4. Mandatory Nature of Consent
– Specific recordings: optional consent; the data subject may request not to be included or to have their images removed (Art. 6(1)(a) GDPR).
– Panoramic/overview recordings: refusal of consent does not prevent publication of general content in which the data subject may appear incidentally; this processing is based on legitimate interest (Art. 6(1)(f) GDPR, Art. 2-sexies Legislative Decree 196/2003, Recital 47 GDPR).

5. Data Subject Rights
Rights of access, rectification, erasure, restriction, objection, portability, and withdrawal of consent (Arts. 15–22 GDPR).
Requests should be sent to info@blwrk.fit.

6. Revision Date
2 May 2025

Pursuant to Article 122 of Legislative Decree No. 196/2003 (Privacy Code), Regulation (EU) 2016/679 (GDPR) and Directive 2009/136/EC (ePrivacy)

1. What are cookies
– Cookies are small text files stored on your device (computer, tablet, smartphone) when you visit a website.
– They allow the site to “remember” information about your browsing preferences and improve your user experience.

2. Types of cookies
2.1 Technical cookies
– Necessary for the website to function and to provide requested services (e.g. session management, authentication).
– Do not require your prior consent.

2.2 Functional cookies
– Allow the site to remember choices you make (e.g. language, region) to enhance navigation.
– Do not aggregate data for other purposes.

2.3 Profiling cookies
– Collect information about your browsing habits to deliver advertising tailored to your interests.
– Require your explicit prior consent (Art. 6(1)(a) GDPR).

2.4 Third-party cookies
– Set by domains other than www.blwrk.fit (e.g. Google Analytics, Facebook, YouTube).
– May fall into any of the categories above: technical, functional or profiling.

3. Purposes of processing
– Ensure the correct functioning of the website.
– Personalize your browsing experience.
– Analyse traffic and usage statistics (via analytics cookies).
– Deliver targeted advertising in line with your expressed preferences.

4. Managing and withdrawing consent
– On your first visit, a banner will appear with a link to this Cookie Policy and buttons to accept or reject non-technical cookies.
– You can change your preferences at any time by clicking the “Cookie settings” icon at the bottom of each page.
– Disabling profiling and third-party cookies may limit certain website features and result in less relevant advertising.

5. Indicative list of cookies used
– Technical cookies (Blwrk.fit)
– Cookie name: PHPSESSID
– Duration: session
– Purpose: user session management

– Functional cookies (Blwrk.fit)
– Cookie name: lang
– Duration: 1 year
– Purpose: remember preferred language

– Analytics cookies (third party) (Google Analytics)
– Cookie names: _ga, _gid
– Duration: 2 years (_ga), 24 hours (_gid)
– Purpose: anonymous traffic statistics

– Profiling cookies (third party) (Google AdSense)
– Cookie name: IDE
– Duration: 1 year
– Purpose: behavioural advertising

6. Data subject rights
– You have the right of access, rectification, erasure, restriction, objection, portability and withdrawal of consent (Arts. 15–22 GDPR).
– You may withdraw consent to non-technical cookies at any time via the banner settings or your browser settings.
– To exercise your rights, send a request to info@blwrk.fit.

7. Changes to this Cookie Policy
– This Policy may be updated to reflect new legal or technical requirements.
– Any changes will be published with a new Revision Date.

8. Revision Date
2 May 2025

Acceptance of these Terms is mandatory to use any service provided by Bulwark s.s.d. a R.L.

1. Scope of Application
This Regulation governs the terms and conditions for accessing and participating in activities organized by Bulwark. By subscribing to a Membership, the Client expressly accepts its entire content.

2. Sports Season
The sports season runs from 1 September to 31 August of the following year.

3. Membership and Registration
– Access to the facilities is reserved exclusively for registered members, subject to Bulwark’s unquestionable approval.
– Annual registration fee: € 30, non-refundable and non-suspendable.
– The “Sign-In” Membership commences on the first day of the month of subscription.

4. Medical Certificate
– Upon initial registration and at each annual renewal, the Client must provide a valid medical certificate confirming fitness for physical activity.
– In the absence of, or failure to renew, the medical certificate, Bulwark may suspend access until compliance.
– The Client agrees to follow all medical prescriptions and refrain from prohibited or inadvisable activities; Bulwark is not liable for injuries resulting from the Client’s failure to comply.

5. Subscriptions
5.1 Automatic Renewal
– All subscriptions renew automatically under the same conditions.

5.2 Amendments and Suspensions
– Subscriptions are neither amendable nor suspendable, except as provided in section 5.4.

5.3 Cancellation for Serious Reasons
– In the event of (i) a serious injury with a prognosis exceeding one month or (ii) a change of residence, the Client may request termination of automatic billing without penalty.
– Procedure: send an email to info@blwrk.fit with supporting documentation; cancellation takes effect from the invoice following receipt.

5.4 Ordinary Cancellation
– For any other reason, cancellation is permitted upon payment of a penalty equal to one unpaid monthly installment.

5.5 Force Majeure
– In case of forced closure (e.g. governmental orders, health emergencies), the subscription is temporarily suspended; any inactive period will be made up at the end of the contractual term without further extension.

6. Rules of Conduct and Use of Facilities
6.1 Conduct
– Maintain correct, courteous, and respectful behavior at all times.
– Dangerous or violent conduct is strictly prohibited.

6.2 Attire
– Wear appropriate and decent sportswear.
– Only indoor sports shoes are permitted.

6.3 Booking
– Lessons must be booked via the app up to a few minutes before start time.
– Classes with zero bookings one hour before start will be automatically cancelled.
– Cancellations more than one hour in advance are free of charge.
– Late cancellations (within one hour) incur a € 1 penalty (plus fees) and forfeiture of entry.

6.4 Equipment and Hygiene
– Always use a towel on benches and mats.
– Return, clean, and sanitize equipment after use.
– Any damage to facilities or equipment must be compensated by the responsible party.

6.5 Personal Belongings
– Do not leave personal items unattended in the training area; use lockers provided.
– Bulwark declines all liability for loss or damage to personal items.

6.6 Minors
– Children are not permitted in the training area during sessions without direct adult supervision.

6.7 General Prohibitions
– Smoking and eating are prohibited in all areas of the Box.

7. Effective Date and Acceptance
This Regulation comes into force on 1 September 2014.
By subscribing to a Membership, the Client acknowledges having read, understood, and accepted all the above terms.

8. Revision Date
2 May 2025

This Code of Conduct summarizes the core principles that all members, collaborators, and staff of Bulwark s.s.d. a R.L. are expected to uphold in the context of sporting and associative activities.

1. General Principles
– Responsibility: everyone is accountable for their own actions and the consequences thereof.
– Loyalty: act with fairness, mutual respect, and cooperation.
– Non-violence: abstain from any conduct that may harm others physically or morally.
– Inclusion: welcome and treat all individuals with equal dignity, without discrimination on the basis of race, ethnicity, gender, sexual orientation, disability, age, religion, or beliefs.

2. Integrity and Fairness
– Prohibition of doping and harmful practices: comply with anti-doping regulations and safeguard health.
– Truthfulness and respect: refrain from making defamatory or offensive statements about individuals or sporting organisations.

3. Digital Conduct
– Privacy and confidentiality: respect others’ personal data and do not share it without authorisation.
– Social etiquette: use online channels and communication platforms responsibly and respectfully.

4. Well-being and Sustainability
– Care for self and others: be mindful of mental well-being and offer mutual support.
– Eco-awareness: use resources responsibly and respect shared spaces.

5. Prevention and Reporting
– Harassment and inappropriate behaviour: do not tolerate any form of harassment or intimidation.
– Support channels: all reports will be treated confidentially and addressed promptly.

6. Effective Date
This Code comes into force on 1 September 2014 and is binding on all members and collaborators. By joining Bulwark, you acknowledge having read, understood, and accepted these terms.

7. Revision Date
2 May 2025