MP Girl Data Protection Policy, Consent and Image Use

1. Data Controller

The controller responsible for processing the personal data collected within the scope of the MP Girl Program is:

MP Gymnastics by Indexdivision Lda.
VAT No.: 515815624
Rua Instituto Conde de Agrolongo 25A
2770-082 Paço de Arcos
Portugal

Email: support@mp-gymnastics.com

Hereinafter referred to as "MP Gymnastics."

2. Purpose of this Policy

This Data Protection, Consent and Image Use Policy governs the collection, use, processing, storage, and sharing of personal data within the scope of the MP Girl Program, including the participation of minors, the use of User Generated Content (UGC), image and voice rights, and participation in digital communities and brand activations.

Participation in the MP Girl Program implies that participants have read, understood, and accepted this Policy, without prejudice to the requirement to obtain any legally required consents.

3. Purpose of Data Collection

The personal data collected will be used exclusively for the following purposes:

  • managing and validating applications;
  • communicating with participants and, where applicable, their parents, legal guardians, or legal representatives;
  • managing the MP Girl community;
  • organizing and promoting activations, campaigns, and events;
  • sending communications relating to the Program and the brand;
  • managing creative challenges, content creation activities, and submitted content;
  • selecting participants for MP Gymnastics campaigns and initiatives;
  • using content submitted and created by participants;
  • promoting the brand's campaigns, products, and initiatives;
  • complying with applicable legal obligations.

4. Personal Data Collected

MP Gymnastics may collect the following personal data:

Participant Data

  • full name;
  • age;
  • city and country of residence;
  • telephone number;
  • email address;
  • social media profiles;
  • photographs;
  • videos;
  • User Generated Content (UGC) created within the scope of the MP Girl Program.

Parent, Legal Guardian or Legal Representative Data (where applicable)

  • full name;
  • telephone number;
  • email address;
  • declaration or proof of consent.

5. Participation of Minors

Participation by minors in the MP Girl Program is subject to the prior express authorization of their parent, legal guardian, or legal representative.

By authorizing the participation of a minor, the parent, legal guardian, or legal representative declares that they:

  • have read and understood the MP Girl Program Terms and Conditions, as well as this Policy;
  • accept this Data Protection, Consent and Image Use Policy;
  • authorize the collection and processing of the personal data required for participation in the Program;
  • authorize the minor's inclusion in the MP Girl community;
  • authorize the minor's participation in creative challenges, activations, and initiatives promoted by MP Gymnastics;
  • authorize the capture and use of the minor's image and content under the terms set out in this Policy.

MP Gymnastics reserves the right to request additional documentation or proof of consent whenever deemed necessary.

6. Voluntary Participation

Participation in the MP Girl Program is entirely voluntary.

Participants or, where applicable, their parent, legal guardian, or legal representative may request to withdraw from the Program or leave the MP Girl community at any time by notifying MP Gymnastics.

Likewise, MP Gymnastics reserves the right to suspend, restrict, or terminate the participation of any participant whenever it considers that there has been:

  • a breach of the Program Terms and Conditions;
  • inappropriate behaviour;
  • misuse of the community or its communication channels;
  • offensive language;
  • spam;
  • conduct that is harmful to the brand, the community, or third parties.

7. Image and Content Usage Rights

By participating in the MP Girl Program and submitting content to MP Gymnastics, the participant and, where applicable, their parent, legal guardian, or legal representative grant MP Gymnastics, free of charge, the right to use their image, voice, name, photographs, videos, and content created within the scope of the Program.

This grant includes the right to use, reproduce, adapt, edit, publish, communicate, and distribute such content for commercial, promotional, and institutional purposes in digital, graphic, audiovisual, editorial, or printed formats, including but not limited to:

  • social media;
  • the official website and online store;
  • partner online stores;
  • digital campaigns;
  • advertising;
  • newsletters;
  • promotional materials;
  • corporate presentations;
  • catalogues;
  • future brand campaigns;
  • other initiatives related to MP Gymnastics' activities.

This authorization is granted free of charge. Accordingly, participation in the MP Girl Program does not guarantee any financial compensation, remuneration, commercial partnership, exclusive representation arrangement, or participation in specific MP Gymnastics campaigns, unless otherwise agreed in writing between the parties.

8. Previously Published Content

Withdrawal of consent, departure from the community, or termination of participation in the MP Girl Program shall apply prospectively only and shall not require MP Gymnastics to remove content, campaigns, or promotional materials that have already been published or produced within the scope of the Program, where such removal would result in a disproportionate technical, operational, or commercial impact on the brand, without prejudice to case-by-case assessment.

9. Content Selection, Moderation and Management

The submission of content within the scope of the MP Girl Program does not guarantee its use, publication, republication, or inclusion in campaigns, digital platforms, or promotional materials of the brand.

MP Gymnastics reserves the exclusive right to select, use, edit, publish, or decline to publish any content submitted by participants within the scope of the MP Girl Program, at its sole discretion and based on creative, editorial, strategic, and brand alignment criteria.

MP Gymnastics may also decide not to use content that:

  • is not aligned with the brand's visual identity or communication style;
  • does not meet the technical or creative quality standards considered appropriate;
  • is not aligned with specific campaigns, collections, or objectives;
  • is deemed inappropriate;
  • may harm the brand's image or reputation;
  • infringes the rights of third parties;
  • contains offensive language or inappropriate content.

MP Gymnastics further reserves the right to edit, adapt, crop, or otherwise adjust submitted content for publication or integration into its platforms and campaigns.

10. WhatsApp Community, Communication Platforms and Third Parties

The MP Girl Program may make use of third-party communication platforms and social media networks, including WhatsApp, Instagram, TikTok, Meta Platforms, or other digital tools.

The use of such platforms is also subject to the respective terms and policies of their owners, without prejudice to the legal obligations incumbent upon MP Gymnastics as a data controller.

MP Gymnastics shall not be responsible for:

  • technical failures of third parties beyond its control;
  • platform downtime or unavailability;
  • operational changes to third-party platforms;
  • third-party policies;
  • technical limitations;
  • or any other circumstances outside its direct control.

Participants may be added to communication groups associated with the MP Girl Program, namely through WhatsApp or other communication platforms designated by the brand.

In the case of minor participants who do not have their own mobile phone or direct access to WhatsApp, participation in the community may be facilitated through the contact details of their parent, legal guardian, or legal representative.

By participating in such groups, participants and/or their parents, legal guardians, or legal representatives acknowledge that:

  • other members may be able to view the name and telephone number associated with their account;
  • participation must comply with the community rules;
  • MP Gymnastics may remove participants who fail to comply with the Program rules.

11. Data Sharing

MP Gymnastics does not sell personal data to third parties.

Personal data may, where necessary, be shared with suppliers, partners, or service providers directly involved in the operational management of the MP Girl Program, including for the purposes of:

  • campaign management;
  • event organization;
  • communication platforms;
  • marketing tools;
  • content production;
  • technical and operational management of the community.

Where applicable, MP Gymnastics will seek to ensure that such entities comply with the applicable data protection legislation by implementing appropriate contractual safeguards relating to the protection of personal data.

12. Data Retention

Personal data will be retained only for the period necessary to fulfil the purposes for which it was collected in connection with the MP Girl Program and the brand's related initiatives, without prejudice to any applicable statutory retention periods.

Different retention periods may apply to application data, validation records, consent forms, communications, submitted content, and administrative records, depending on their respective purposes.

MP Gymnastics may retain certain content and records for as long as there is a legitimate interest in doing so, including for brand management, marketing campaigns, promotional archives, or the historical record of its initiatives.

13. Data Subject Rights

In accordance with the applicable legislation, data subjects or, where applicable, their parents, legal guardians, or legal representatives, may request:

  • access to their personal data;
  • rectification of inaccurate personal data;
  • erasure of their personal data;
  • restriction of processing;
  • objection to the processing of their personal data;
  • withdrawal of any consent previously given.

Requests should be submitted to:

support@mp-gymnastics.com

The withdrawal of consent shall not affect the lawfulness of any processing carried out prior to its withdrawal.

14. Data Security

MP Gymnastics undertakes to implement appropriate technical and organizational measures to protect personal data against:

  • loss;
  • misuse;
  • unauthorized access;
  • improper disclosure;
  • alteration;
  • destruction.

However, no transmission of data over the internet or through digital platforms can be guaranteed to be completely secure.

15. Amendments to this Policy

MP Gymnastics reserves the right to update, amend, or adapt this Data Protection, Consent and Image Use Policy whenever necessary.

Updated versions may be communicated through the brand's official communication channels.

16. Acceptance of this Policy

Participation in the MP Girl Program constitutes confirmation that the participant has read, understood, and fully accepted this Data Protection, Consent and Image Use Policy.

 
MP Girl Program