Last updated 23 August 2026

This privacy notice for thurstonmartialarts.com ("we", "us" or "our") describes how and why we might collect, store, use and/or share ("process") your information when you use our services ("Services"), such as when you:

Visit our website at thurstonmartialarts.websites.efcaquila.com, or any website of ours that links to this privacy notice
Use the member app and online forms we provide, or any other application of ours that links to this privacy notice
Engage with us in other related ways, including any enquiries, trial classes, enrolments, events or marketing

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you have any questions or concerns, please contact us using the details in section 13.

Who provides our website and billing

EFC International Development ("EFC") is the service provider that hosts this website, receives and stores the enquiries you submit through it, and administers tuition billing and communications on our behalf. When you pay fees to us, EFC collects those payments as our authorised billing agent, and your payment card or bank account details are handled by EFC and its regulated payment providers for that purpose.

EFC processes this information on our instructions and under our agreement with it. It is not a party to your agreement with us: we remain responsible for your personal information as the "data controller" (or "business"), and EFC acts as our "data processor" (or "service provider").

For data protection queries about EFC's processing on our behalf, you can contact EFC at:

EFC International Development
15 Commercial Road, Metropolis, Metro, ME1 4FC
devtest@efcuk.org.uk
01234 556445

1. What information do we collect?

Personal information you disclose to us

In short: we collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you enquire about or register for our classes, express an interest in obtaining information about us or our Services, take part in activities on the Services, or otherwise contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. It may include the following:

names
phone numbers
email addresses
mailing addresses
dates of birth
emergency contact details
usernames and passwords
contact preferences
billing addresses
debit/credit card numbers and bank account details

Sensitive information. We do not collect sensitive information through this website.

Information about children. Many of our students are children. Where a student is under 18, we collect the student's details (such as their name and date of birth) from their parent or guardian, together with the parent's or guardian's own contact and billing details, and we treat the parent or guardian as our point of contact. We do not knowingly collect personal information directly from children online; our website and forms are intended to be completed by adults. If you believe a child has given us personal information directly, please contact us using the details in section 13 and we will delete it.

Application data. If you use the member app we provide, we may ask for access to certain features of your mobile device (such as its camera) and for permission to send you push notifications about your account. You can change either at any time in your device's settings. This information is primarily needed to maintain the security and operation of the app, for troubleshooting, and for our internal analytics and reporting.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to it.

2. How do we process your information?

In short: we process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To respond to your enquiries and offer support. To respond to your enquiries, arrange a trial class and solve any potential issues you might have with the requested service.
To deliver our Services. To enrol you or your child, run and record classes and gradings, and manage memberships.
To manage your account. So you can create and log in to an account in the member app, and to keep it in working order.
To send administrative information to you. Details about your classes and membership, changes to our terms and policies, and other similar information.
To collect fees and manage payments. To collect fees, manage payments, refunds and payment methods, and keep the financial records the law requires.
To tell you about our classes and events. We may send you marketing about our classes, events and offers where you have agreed to it or where the law otherwise allows. You can opt out at any time; see section 8.
To save or protect an individual's vital interest. When necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In short: we only process your personal information when we believe it is necessary and we have a valid legal reason (a legal basis) to do so under applicable law — with your consent, to comply with laws, to provide you with services, to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

Consent. We may process your information if you have given us permission (consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services, or at your request prior to entering into a contract with you.
Legitimate interests. We may process your information when it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms — for example, following up an enquiry you made, keeping attendance and membership records, and improving our Services.
Legal obligations. We may process your information where it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital interests. We may process your information where it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms we are the "data controller" under European data protection laws of the personal information described in this privacy notice, since we determine the means and purposes of the processing. EFC processes that information on our behalf as our "data processor", as described above.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent — for example, where collection is clearly in an individual's interests and consent cannot be obtained in a timely way; for investigations, fraud prevention and insurance claims; for business transactions provided certain conditions are met; to identify injured, ill or deceased persons and communicate with next of kin; where we reasonably believe an individual may be the victim of financial abuse; where seeking consent would compromise an investigation into a breach of an agreement or of the laws of Canada or a province; to comply with a subpoena, warrant, court order or rules of the court; or where the information is publicly available and specified by the regulations.

4. When and with whom do we share your personal information?

In short: we may share information in the specific situations described in this section and with the following third parties.

Our service provider, EFC. EFC hosts this website, stores the enquiries you submit and administers billing and communications on our behalf, as described above.
Payment providers. Fees are collected through regulated payment providers (for example, card and bank-debit processors) engaged by EFC on our behalf, who receive the payment details needed to take a payment.
Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we use cookies and other tracking technologies?

In short: we may use cookies and other tracking technologies to collect and store your information.

Our website may use cookies and similar tracking technologies (like web beacons and pixels) to measure how the site is used and to make our advertising more relevant. Where the law requires it, we ask for your consent before setting non-essential cookies, and you can change your choice at any time. Most web browsers also let you remove or reject cookies; if you do, some features of the Services may not work as intended.

6. How long do we keep your information?

In short: we keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). In general that means for as long as you or your child are a member or prospective member with us, and afterwards for as long as we need to keep records of that relationship. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because it has been stored in backup archives), securely store it and isolate it from any further processing until deletion is possible.

7. How do we keep your information safe?

In short: we aim to protect your personal information through a system of organisational and technical security measures.

We and EFC have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Transmission of personal information to and from our Services is at your own risk, and you should only access the Services within a secure environment.

8. What are your privacy rights?

In short: in some regions, such as the European Economic Area (EEA), United Kingdom (UK) and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change or terminate your account at any time.

In some regions (like the EEA, UK and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access to and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the details in section 13, and we will consider and act upon it in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw it at any time by contacting us using the details in section 13. This will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, processing conducted in reliance on lawful grounds other than consent.

Opting out of marketing. You can stop marketing text messages at any time by replying STOP, unsubscribe from marketing emails using the link in any of them, or contact us using the details in section 13. We may still send you messages that are necessary to administer your membership.

Account information. If you would like to review or change the information in your account or close your account, you can update it in the member app or contact us using the details in section 13. When you ask us to close your account, we will deactivate or delete it from our active databases, though we may retain some information to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

9. Controls for do-not-track features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") setting to signal your preference not to have your online browsing activities monitored and collected. No uniform standard for recognising DNT signals has been finalised, so we do not currently respond to DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard we must follow is adopted, we will say so in a revised version of this privacy notice.

10. Do California residents have specific privacy rights?

In short: yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83 (the "Shine The Light" law) permits California residents to request from us, once a year and free of charge, the categories of personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year, and those third parties' names and addresses. To make such a request, write to us using the details in section 13.

If you are under 18, reside in California, and have a registered account with the Services, you may request removal of unwanted data that you publicly post on the Services: contact us using the details in section 13 with the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed, though it may not be completely removed from all our systems (for example, backups).

CCPA privacy notice

If you are a California resident within the meaning of the California Code of Regulations, we must adhere to certain rights and obligations regarding your personal information under the California Consumer Privacy Act (CCPA).

What categories of personal information do we collect? We have collected the following categories of personal information in the past twelve (12) months:

A. Identifiers: contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.
B. Personal information categories listed in the California Customer Records statute: name, contact information and financial information.
C. Protected classification characteristics under California or federal law: gender and date of birth.

We use and retain each of these categories as needed to provide the Services and for as long as you or your child are a member or prospective member with us.

Will your information be shared with anyone else? We may disclose your personal information to our service providers pursuant to a written contract, and each of them processes it on our behalf under the same strict privacy obligations the CCPA mandates. We may also use your personal information for our own business purposes, such as internal research for technological development; this is not "selling" your personal information. We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months, and we will not sell or share personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

Right to request deletion. You can ask for the deletion of your personal information, and we will respect your request subject to the exceptions provided by law — for example, another consumer's exercise of their right to free speech, our compliance with a legal obligation, or processing required to protect against illegal activities.
Right to be informed. Depending on the circumstances, you have a right to know whether we collect and use your personal information; the categories we collect and the purposes we use them for; whether we sell or share personal information to third parties, and the categories of personal information and of third parties involved; and the specific pieces of personal information we collected about you. We are not obligated to provide or delete consumer information that is de-identified, or to re-identify individual data to verify a request.
Right to non-discrimination. We will not discriminate against you if you exercise your privacy rights.
Right to limit use and disclosure of sensitive personal information. We do not process consumers' sensitive personal information.
Right to opt out. You may request to opt out from any future selling or sharing of your personal information to third parties; we will act on such a request no later than fifteen (15) days from its submission.

Verification process. On receiving your request we will need to verify your identity — by matching information you give us against what we already hold, or by contacting you through a phone number or email address you have previously given us. We use the information in your request only to verify your identity or authority to make it, and we delete any additional information provided for verification as soon as we finish verifying you.

Other privacy rights. You may object to the processing of your personal information, request correction of personal data that is incorrect or no longer relevant, or ask to restrict its processing. You can designate an authorised agent to make a request under the CCPA on your behalf; we may deny a request from an agent that does not submit proof of valid authorisation. To exercise these rights, contact us using the details in section 13. If you have a complaint about how we handle your data, we would like to hear from you.

11. Do Virginia residents have specific privacy rights?

In short: yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Virginia CDPA privacy notice

Under the Virginia Consumer Data Protection Act (CDPA), a "consumer" is a natural person who is a resident of the Commonwealth acting only in an individual or household context, and "personal data" is any information linked or reasonably linkable to an identified or identifiable natural person (excluding de-identified or publicly available information). If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data. The sections above describe the personal data we collect, how we use it, and when and with whom we share it.

Your rights with respect to your personal data

Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

We have not sold any personal data to third parties for business or commercial purposes, and we will not sell personal data in the future belonging to website visitors, users and other consumers.

Exercising your rights. Contact us using the details in section 13. If you use an authorised agent, we may deny a request without proof of valid authorisation, and we may ask for information reasonably necessary to verify you and your request. We will respond without undue delay and within forty-five (45) days of receipt; that period may be extended once by forty-five (45) days when reasonably necessary, and we will tell you within the initial period if it is.

Right to appeal. If we decline to take action regarding your request, we will inform you of our decision and the reasoning behind it. To appeal, contact us using the details in section 13; within sixty (60) days of receipt we will inform you in writing of any action taken or not taken, with our reasons. If your appeal is denied, you may contact the Attorney General to submit a complaint.

12. Do we make updates to this notice?

In short: yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "last updated" date and will be effective as soon as it is accessible. If we make material changes, we may notify you by prominently posting a notice of them or by sending you a notification directly. We encourage you to review this privacy notice frequently.

13. How can you contact us about this notice?

If you have questions or comments about this notice, or about how we handle your personal information, please contact us:

thurstonmartialarts.com
409 Columbia Road, Hanover, Massachusetts, 02339
thurstonmartialarts@gmail.com
(781) 936-8666

For queries about EFC's processing on our behalf — including billing — you can also contact EFC:

EFC International Development
15 Commercial Road, Metropolis, Metro, ME1 4FC
devtest@efcuk.org.uk
01234 556445

14. How can you review, update or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To do so, please contact us using the details in section 13.

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