Gunbix › Data processing agreement between the Club and Takion

Version 1.3 - In force since 30 August 2026

Data processing agreement (Article 28 GDPR)

Read before signing. This text is a draft prepared in-house by Takion. It has not been reviewed by a lawyer. It is usable as it stands in order to understand who does what and to bind the parties, and it provides for its own replacement by the reviewed version (Article 15). This reservation will disappear from that version.

Why this agreement exists

When a club uses Gunbix to track its members' documents, to keep its entry register or to migrate its file, two different persons act on the same data.

The Club decides: it is the Club that chooses to require a medical certificate, an up-to-date membership fee or a federation licence, that examines the documents, that draws the consequences for its members, that is approved to operate a range and that is required by law to keep the register. In data protection law, the one who decides is the controller.

Takion performs: it supplies the tool, stores, serves and erases, but it decides neither what is required, nor who is in good standing, nor who enters the range. The one who performs on behalf of another is the processor.

Article 28 GDPR prohibits a controller from entrusting data to a processor without a written contract setting out what that processor may and may not do. This is that contract.

Between the parties

On the one hand, the Club, identified in its Gunbix space by its statutory name, its legal form, its company number, its registered office and the name of the signatory who binds it. These elements are set out in Annex 0 and are frozen at the time of acceptance. Hereinafter the Club or the Controller.

On the other hand, TAKION SRL, a private limited liability company incorporated under Belgian law, registered office at Rue Mansart 39/A, 7534 Tournai (Belgium), registered with the Crossroads Bank for Enterprises under number 1014.464.305, represented by its managing director Giannino Cuignet, hereinafter Takion or the Processor.

Data protection contact: privacy@takion.be

Article 1 - Purpose and order of precedence of documents

This agreement governs the processing of personal data that Takion carries out on behalf of the Club in connection with the Gunbix service, as described in Annex 1.

It supplements the Gunbix terms of use. In the event of a contradiction on a data protection matter, this agreement prevails.

It does not cover processing for which Takion is itself the controller: the management of user accounts, a User's firearms inventory and shooting sessions, platform security, and billing. Those are described in the Gunbix privacy policy.

Article 2 - Conclusion, entry into effect and duration

The agreement is concluded by the Club's acceptance within the Service, under the conditions of Article 2 bis. It takes effect on the date of that acceptance.

Until it is accepted, the Service refuses to open the processing operations set out in Annex 1. That refusal is technical and depends on no human act at Takion. It applies to opening and to new entries; it never applies to consulting, extracting or erasing data already entrusted, nor to continuing an entry register already opened, which the regulations require the Club to keep.

The agreement runs for as long as the Club uses the Service. It survives the end of the relationship as regards the return and erasure of data (Article 11) and confidentiality (Article 4).

Article 2 bis - Acceptance, evidence and change of version

Who accepts. A natural person holding administrator access to the club within the Service, who expressly declares that they have the power to bind the Club. That declaration is recorded together with their name and function.

What is retained. For each acceptance, the Service retains, for as long as the Club exists: the name, legal form, company number and registered office of the Club as they stood on the day of acceptance; the name and function of the signatory; the date and time; the originating address of the connection, truncated after ninety days; the version number of this agreement and the cryptographic fingerprint of the text accepted. That fingerprint makes it possible to establish, years later, exactly which text was accepted.

What is provided to the Club. A timestamped document setting out these elements, the full text of the agreement, and Takion's signature for the version concerned. A Club that prefers a hand-signed copy may request one at privacy@takion.be.

Change of version. Takion informs the Club of any substantial new version thirty (30) days before it enters into force, by notification within the Service and by email to the Club's contact address. On expiry of that notice period, a new acceptance is required for new entries, under the same conditions and with the same reservations as in Article 2. A correction that diminishes no right of the Club and no obligation of Takion, in particular the factual updating of an annex, takes effect without notice and is signalled within the Service.

Article 3 - Instructions of the Controller

Takion processes the data only on documented instructions from the Club. The following are deemed to constitute those instructions:

  1. this agreement and its Annex 1;
  2. the settings the Club defines itself within the Service: the documentary requirements it declares, their period of validity, whether they are blocking, the opening of an entry register, the decision to import a membership file, the allocation of roles to its officers and validators;
  3. the written requests the Club sends to privacy@takion.be.

Takion informs the Club if an instruction appears to it to constitute an infringement of the GDPR or of another applicable provision, and may suspend its execution pending written confirmation.

A limit assumed by design. The Club cannot instruct Takion to store a criminal record extract or any other document relating to criminal convictions. The Service refuses to accept such a document, and that refusal is not configurable. The Club has available the attestation without a document ("original seen and received"), which produces the same legal effect for its file without any document entering the system. This limit protects the Club as much as Takion.

A second limit. The Club cannot instruct Takion to make an entry in the entry register disappear before the end of its statutory retention period, nor to alter its kind of visit or its entry and exit times. An erroneous entry is cancelled by a marker, never by deletion, and the correction of another field preserves the previous value in the Club's log. That is what the Royal Decree of 4 May 2018 expects of a register kept by computerised means.

Article 3 bis - Measurement of email delivery and reading

Delivery. Takion measures the fate of the emails it delivers on behalf of the Club (accepted, rejected, deferred, reported as spam). That measurement is necessary to carry out the Club's instruction - to get a message to its members - and forms part of this agreement. Takion reports on it to the Club in the form of the number of recipients reached and the addresses that failed. No email address, no subject, no message body, no IP address and no user agent is retained in those events: they are attached to the recipient's account, and an event concerning an address without an account no longer designates anyone.

Reading. The measurement of the opening of an email and of clicks on the links it contains is not covered by this agreement, and the Club cannot instruct it at this time. It is not enabled: the corresponding settings are empty in the deployed configuration of the Service, and not merely unused.

Were it to be enabled, the roles would be shared as follows, and the parties agree this now:

  1. the Club remains the controller for the content of the message and the list of its recipients;
  2. Takion is the controller, and not the processor, for the measurement mechanism itself: it is Takion that decides to place a pixel in the template common to all the Service's emails, that determines its purpose and means, and that obtains the recipient's consent within that recipient's Gunbix account. Article 28(10) GDPR attaches that capacity to the one who determines the purposes and means;
  3. no email addressed to a person who has not given that consent is instrumented, whatever the Club's instruction, and no email addressed to a person under the age of eighteen is instrumented in any circumstances;
  4. no open or click statistics are provided to the Club until point 2 has been recorded by an amendment to this agreement: providing the Club with a measurement made for it would make the Club the controller, and would change the person who must obtain consent.

Article 4 - Confidentiality

Takion ensures that every person it authorises to process the data is bound by an obligation of confidentiality, whether statutory or contractual, and accesses the data only to the extent strictly necessary for the performance of the service.

The Club gives the same undertaking for its officers, its validators and any person to whom it opens access within the Service, and keeps the list of the persons concerned together with a description of their function, in accordance with Articles 9 and 10 of the Belgian Act of 30 July 2018 where health data or judicial data is involved.

Article 5 - Security

Takion implements the technical and organisational measures described in Annex 2, appropriate to the risk and to the state of the art. It may develop them, provided it does not reduce the level of protection.

Annex 2 contains a section "What these measures do not cover". This is not boilerplate: it enumerates the protections that Takion knows it does not have in place. The Club takes them into account in its own assessment and in choosing the data it entrusts.

The Club acknowledges that the security of its own access is its responsibility: the choice of the persons to whom it entrusts a role, the withdrawal of that role when an officer leaves, and the vigilance of its members over their accounts.

Article 6 - Sub-processors

The Club authorises Takion to engage the sub-processors listed in Annex 3.

Takion informs the Club of any addition or replacement at least thirty (30) days before it takes effect, by notification within the Service and by email to the Club's contact address. The same notice period applies to the entry into service of a sub-processor listed in Annex 3 as not active. The Club may object on reasonable grounds relating to data protection; failing agreement, it may terminate its use of the Service without charge or penalty.

Takion imposes on every sub-processor protection obligations equivalent to those of this agreement, and remains fully liable to the Club for their performance.

Article 7 - Location and transfers outside the European Economic Area

What is constrained. The storage of uploaded files (documents, photographs, avatars) is provided by a container created in the European Union jurisdiction: the constraint is set at creation and depends on no setting.

What is observed without being constrained. The database that holds the other data is located in Western Europe. That location is an indication given to the provider, not a contractual guarantee of residency: a jurisdiction can only be set when a database is created, and that operation has not been carried out. Takion will inform the Club when it has been. The Club cannot therefore, as matters stand, assure its members that their data benefits from constrained European residency at database level.

Execution. The Service's code runs on the provider's global network, at the edge, which implies possible processing from a third country.

Transfers. Emails addressed to members on behalf of the Club are delivered by a provider established in the United States (Annex 3). Those transfers, and incidental technical access from a third country, are governed by the standard contractual clauses adopted by the European Commission on 4 June 2021, supplemented by encryption in transit and encryption at rest provided by the hosting provider.

Article 8 - Assistance to the Controller

Taking into account the nature of the processing and the information available to it, Takion assists the Club:

The Club remains solely responsible for carrying out its impact assessment where one is required, and for keeping its own records of processing. Takion's platform assessment does not take its place: it knows neither the number of the Club's members, nor the number of persons to whom the Club opens access, nor the requirements the Club decides upon.

Article 9 - Personal data breach

Takion notifies the Club of any personal data breach affecting the data processed on its behalf, without undue delay and at the latest within forty-eight (48) hours of becoming aware of it, at the Club's contact address.

The notification describes the nature of the breach, the categories and approximate number of data subjects concerned, the likely consequences and the measures taken or envisaged.

Notification to the Data Protection Authority and, where applicable, to the data subjects, is a matter for the Club, in its capacity as controller.

Article 10 - Processor's records of processing

Takion keeps records of the processing carried out on behalf of its controller clients, in accordance with Article 30(2) GDPR. The sheets corresponding to this agreement are sheets 14 (document cycle and licence file), 15 (range register), 16 (imported members) and 18 (member attendance register) of its internal records, kept available to the Data Protection Authority.

Article 11 - Fate of the data at the end of the agreement

At the end of the relationship, and at the Club's choice expressed in writing within thirty (30) days:

Failing a choice expressed within that period, Takion proceeds to erasure, with the exception of the entry register, which the Royal Decree of 13 July 2000 requires to be retained for ten years and whose early erasure would put the Club in default. That register is returned to the Club and then erased.

Certain data is erased before the end of the agreement, during the course of the service, because there is no reason to retain it: the bytes of a medical certificate disappear at the moment of the Club's decision, and the bytes of other documents after the periods set out in Annex 1. Those erasures do not depend on a request from the Club: they are carried out by the Service itself, by a daily pass.

Article 12 - Audit

Takion makes available to the Club the information necessary to demonstrate compliance with the obligations of Article 28, in particular the records referred to in Article 10, Annex 2 and the platform impact assessment.

The Club may request an audit, at its own expense, once a year and subject to reasonable notice, carried out by itself or by an independent auditor bound to confidentiality. That audit may not prejudice the security or the confidentiality of other clubs' data.

Article 13 - Liability

Each party is liable for damage caused by processing that infringes its own obligations, under the conditions of Article 82 GDPR.

The limitations of liability provided for in the Gunbix terms of use apply, without being able to obstruct the rights of data subjects or mandatory provisions.

Article 14 - Governing law and jurisdiction

This agreement is governed by Belgian law. Any dispute falls within the jurisdiction of the Enterprise Court of Hainaut, Tournai division, after an attempt at amicable settlement.

Article 15 - Replacement by the reviewed version

This text has not been reviewed by a lawyer, and the Club is informed of this before accepting. When a version reviewed by a legal professional is published, it will replace this one in accordance with the procedure in Article 2 bis. If that reviewed version diminishes no right of the Club and no obligation of Takion, the Club accepts in advance that it shall replace this one without renegotiation, the new acceptance then amounting to a simple acknowledgement.


Annex 0 - Identification of the Club

Completed by the Club at the time of acceptance, and frozen in the evidence of that acceptance.

Item Value
Statutory name
Legal form
Company number (CBE)
Registered office
Address of the range, if different
Range approval number
Contact address for notifications
Name of the signatory
Function of the signatory

Annex 1 - Description of the processing operations

Five distinct processing operations are carried out on behalf of the Club. They share neither the same legal basis, nor the same retention period, nor the same recipients.

1. Member document cycle and sport shooting licence file

Item Content
Subject matter Tracking of the documents the Club requires of its members, and compilation of the file applying for or renewing a sport shooting licence
Nature of the operations Collection, recording, storage, consultation, making available to the Club's authorised staff, erasure
Purpose To enable the Club to establish that a member is in good standing, to follow up those who are not, and to support a licence application
Legal basis of the Club Article 6(1)(b), performance of the membership contract; point (c), legal obligation where the regulations or the federation's rules require verification of a document
Data subjects Members of the Club, including minors aged sixteen to eighteen; officers and validators, as authors of the decisions
Data - administrative Member identifier, requirement concerned, date of lodging, status, wording of the decision ("seen", "received", "transmitted"), author and date of the decision, coded reason for refusal and comment, validity window, licence stage and dates, non-sensitive administrative metadata
Data - documents Bytes of non-sensitive documents (PDF, JPEG, PNG), SHA-256 fingerprint, type and size
Data - civil identity Surname, first name, date of birth, address, postcode, municipality, country, telephone. These fields remain the property of the User's profile and are readable by the Club only through a projection bounded to a file, consented to by the candidate, versioned and revocable. Without that consent entry, the application form does not print
Special categories - health Medical certificate of fitness. The bytes exist between lodging and the Club's decision, and are then erased. After the decision, all that remains is proof that a document was seen or received
Judicial data None. The lodging of a criminal record extract is refused by the Service. All that remains is an administrative attestation drawn up by an officer
Documents specific to a minor candidate Parental authorisation, produced by the Service in the form of a document whose signed original leaves on paper and does not return; declaration of supervision by an adult, without any third-party identity
Retention - proof of validation For the duration of the member's membership of the Club, then twelve (12) months
Retention - bytes, ordinary documents Ninety (90) days after the decision; three hundred and sixty-five (365) days if the submission is never determined
Retention - bytes, medical certificate Erased upon decision. At the latest at ninety (90) days for a submission never determined

2. Range register: visitors and one-day shooters

Item Content
Subject matter To keep the entry register that the Royal Decree of 13 July 2000, Article 3, 4°, requires of the approved operator, for persons who shoot without being members, and to draw up the day card for the occasional shooter
Legal basis of the Club Article 6(1)(c), legal obligation: the 2000 decree for the five particulars of the register, Article 5, third paragraph, 1° of the same decree for the address recorded on the day card, Article 12, first paragraph, 5° of the Act of 8 June 2006 for the date of birth and nationality. For the address of an ordinary visitor, which no text requires, the basis is the Club's legitimate interests and collection remains optional
Data subjects Third parties to the Service. Natural persons without a Gunbix account, who have accepted no terms of use and are usually unaware that the Service exists
Data Surname, first name, kind of visit, postal address (mandatory for a one-day shooter, optional for a visitor), date of birth, nationality, declared club of origin, label of the accompanying member, firearm used (label, type and calibre frozen, never a named inventory firearm), time of entry, time of exit, manner of closing, author of the entry, cancellation marker
Retention - register Ten (10) years from entry, because the decree so requires. A shorter purge would destroy the record the Club is obliged to produce
Retention - address Ten (10) years, with the entry
Retention - date of birth and nationality Twenty-four (24) months, then erasure of those two fields, the entry remaining in place
Integrity An erroneous entry is cancelled by a marker, never by deletion, and follows the same periods. Correction applies to a closed list of fields that excludes the kind of visit and the times; the Club's log retains the field affected and its previous value
Information of data subjects Article 14 GDPR. Takion supplies the text to be displayed at the sign-in desk; displaying it is the Club's act, and the Club owes it
What remains the Club's responsibility The consecutive numbering of the day card, its three copies, sending one copy to the governor competent for the shooter's place of residence within seven days, the prior notification to the local police required for any computerised record-keeping by the Royal Decree of 4 May 2018, and the endorsement of the pages by that same police force for a paper register. None of these acts can be automated; they belong to the operator

3. Member attendance register

Item Content
Subject matter To record the entry and exit of the Club's members at the range, for the same operator obligation as processing 2, and to establish a shooter's practice against their quota
Legal basis of the Club Article 6(1)(c) for the register obligation; point (b) for the attendance certificate provided to the member
Data subjects Members of the Club, with or without a Gunbix account
Data Member identifier, time of entry, time of exit and manner of closing (including automatic closing at the closing time declared by the Club), capacity (shooter or instructor), firearms used in the form of a frozen label, type and calibre, never a named inventory firearm, author of the entry, corrections by addition only
Recipients The authorised staff of the Club concerned, and of that club only. The member for their own entries
Retention Ten (10) years, like the range register and for the same reason
Reservation This period is settled by this agreement and being implemented as at 30 August 2026. It is not yet applied by an automatic purge. Takion reports this gap rather than concealing it

4. Import of the membership file from earlier software

Item Content
Subject matter To bring into Gunbix the membership file the Club kept in earlier software, and the associated attendance history
Legal basis of the Club Article 6(1)(b), performance of the membership contract binding each member to the Club
Data subjects Members and former members appearing in the file, including those who will never create a Gunbix account
Data Surname, first name, date of birth, address, municipality, country, nationality, email address, two telephone numbers, membership number, federation number and licence dates, attendance history
Data filtered out on import National register number, any reference to a criminal record extract or to a medical certificate, photograph. The filtering is automatic and is not configurable
Retention For the duration of membership, then twelve (12) months. The raw source line of the import is erased at ninety (90) days
Reservation The period of membership plus twelve months is settled by this agreement and being implemented as at 30 August 2026. Only the erasure of the raw source line is applied automatically at present
Information of data subjects Article 14 GDPR, within one month of the import. Takion supplies the text; sending it is the Club's act

5. Delivery of emails addressed to members

Item Content
Subject matter To deliver the emails the Club addresses to its members from the Service: bulk message composed by an administrator, automatic reminder of a document approaching expiry, alert for a quarter without a session, summary addressed to staff
Data Member's email address, Club's reply address, subject and body of the message, name of the Club, nature and due date of the document concerned. Recipients are resolved by the Service from the Club's file according to a closed filter, never supplied by the officer's browser; one message goes out per recipient, and no address is disclosed to another member
Ceilings Five hundred recipients per campaign, ten campaigns per day per Club, subject of two hundred characters, body of ten thousand characters
Record retained The subject, the filter applied and the number of recipients are entered in the Club's audit log. The body of the message is not retained
Retention Delivery event: twelve (12) months. Entry in the Club's audit log: according to the period applicable to that log
Open and click measurement None. See Article 3 bis

Annex 2 - Technical and organisational measures

Recorded as at 30 August 2026 against the code of the Service. Each measure in this annex is verifiable in the code and, for most of them, is covered by automated tests.

Communications and storage

Authentication and access

Uploaded files

Traceability and retention

Organisation

What these measures do not cover

This section exists because a Club bases its own impact assessment on Annex 2, and an annex that concealed what Takion knows to be missing would mislead it. Each of these points is the subject of a dated plan.


Annex 3 - Authorised sub-processors

Sub-processor Role Location Active
Cloudflare, Inc. Hosting of the application, execution of the code, database, file storage, delivery network, routing of mail to the published contact points File storage: European Union, constrained jurisdiction. Database: Western Europe observed, without constrained jurisdiction. Execution: global network. See Article 7 yes
Resend, Inc. Delivery of the emails sent on behalf of the Club: bulk message, reminder of a document approaching expiry, alert for a quarter without a session, summary to staff. Data transmitted: member's email address, Club's reply address, subject and body of the message, name of the Club, nature and due date of the document. The provider produces and retains the delivery events for each message. The provider's open and click tracking options are not used United States. Transfers governed by the standard contractual clauses yes
Google Ireland Limited (Firebase Cloud Messaging) Delivery of the push notification accompanying a document reminder or an alert for a quarter without a session. Data transmitted: device token, title and body of the notification European Union, with transfers to Google LLC governed by the standard contractual clauses no. The code exists and issues no call. Its entry into service will be subject to the thirty-day notice period of Article 6

The public and up-to-date list is maintained at https://gunbix.com/en/sub-processors. It additionally includes the providers Takion engages for the processing for which it is itself the controller, which does not fall within this agreement.


Acceptance

This agreement is accepted electronically within the Service, under the conditions of Article 2 bis. The evidence of acceptance sets out the version of the agreement, the cryptographic fingerprint of its text, the identity of the Club, the name and function of the signatory, and the date and time.

For TAKION SRL, this version is signed by Giannino Cuignet, managing director, on the effective date shown at the head of the document. That signature applies to all acceptances of this version.

A Club that prefers a hand-signed copy may request one at privacy@takion.be.

Party Name and function Date Signature
The Club
TAKION SRL Giannino Cuignet, managing director 30 August 2026