Privacy policy

3. PRIVACY POLICY
Last updated: 1 October 2026
This Privacy Policy explains how Arivora, trading through Sem & Devin, handles personal data.
1. Controller
Arivora / Sem & Devin
KvK: 42113205
Dorpstraat 76
9699 PJ Vriescheloo
The Netherlands
Email: Info.SemenDevin@gmail.com
Arivora is the controller of personal data processed for its own business activities.
2. Personal data we may process
Depending on how you use our website and services, we may process:
your name;
email address;
telephone number;
billing and address details;
order number;
payment status;
purchased services;
gaming platform;
EA/console username;
appointment information;
messages you send us;
IP address;
browser and device information;
website usage information;
account information supplied for the performance of a purchased service.
Login information is particularly sensitive from a security perspective and should only be supplied where strictly necessary.
3. Purposes
We may process your information to:
process your order;
provide purchased services;
arrange coaching sessions;
communicate with you;
administer payments and refunds;
provide customer support;
prevent fraud and abuse;
comply with tax and accounting obligations;
resolve payment disputes;
secure our website;
send marketing communications where legally permitted.
4. Legal bases
Depending on the processing, we rely on:
Performance of a contract
For information necessary to process an order or provide your purchased service.
Legal obligation
For information that we must retain for tax, accounting or other statutory requirements.
Legitimate interests
For appropriate fraud prevention, website security, dispute management and business administration where our interests do not override your rights.
Consent
Where consent is legally required, for example certain marketing or non-essential cookies.
5. Payment providers
Payments may be processed by third-party payment providers, such as Shopify Payments or PayPal, depending on the payment methods offered on our website.
Those providers may process information under their own privacy terms and legal responsibilities.
We do not normally receive your complete payment-card details.
6. Shopify
Our online store is hosted using Shopify.
Shopify may process information necessary to operate the store, checkout, fraud prevention and related services.
7. Account credentials
If a service requires account credentials, we will only use those credentials for the purpose for which they were provided.
Credentials should not be retained longer than reasonably necessary for performance of the service.
Customers should change passwords after completion.
8. Sharing information
We may share personal data where necessary with categories of recipients such as:
Shopify;
payment providers;
hosting providers;
email providers;
accounting or bookkeeping providers;
IT/security providers;
competent authorities where legally required.
We do not sell customer personal data.
9. International transfers
Some service providers may process information outside the European Economic Area.
Where applicable, transfers will be handled using safeguards required under applicable privacy legislation.
10. Retention
We retain information only for as long as necessary for the purpose for which it was collected or as required by law.
Financial and administrative information may be retained for the statutory period required under Dutch law.
Other information will be deleted or anonymised when no longer reasonably necessary, unless retention is necessary for a legal claim or other lawful purpose.
11. Your privacy rights
Depending on the circumstances, you may have rights including:
access;
correction;
deletion;
restriction;
objection;
data portability;
withdrawal of consent.
Requests can be sent to:
Info.SemenDevin@gmail.com
12. Complaints
If you have concerns about our processing of personal data, please contact us first.
You also have the right to lodge a complaint with the Autoriteit Persoonsgegevens.
13. Security
We take reasonable technical and organisational measures to protect personal data.
However, no online system can guarantee absolute security.
For security reasons, customers should never reuse their main email, banking or other important passwords as a gaming-account password shared for a service.
14. Cookies
Our website may use:
necessary cookies;
analytics cookies;
preference cookies;
marketing cookies.
Where consent is legally required, optional cookies should not be activated until the visitor has given the required consent.
15. Changes
We may update this Privacy Policy to reflect changes to our services, technology or legal requirements.
The latest version will be published on our website.