- IMPORTANT INFORMATION AND WHO WE ARE
This privacy notice provides you with details of how we collect and process your personal data, including at our physical site(s) and through your use of our website www.lifetransformingfitness.co.uk, including any information you may provide through our site when you purchase a product or service, including memberships, sign up to our newsletter or take part in a prize draw or competition.
Our business, including our website, is not intended for children and we do not knowingly collect data relating to children. By providing us with your data, you warrant to us that you are over 16 years of age.
Our full details are:
Life Transforming Fitness (FAO: Stuart Degville)
Email address: firstname.lastname@example.org
Our location is on our homepage.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful if you would contact us in the first instance so that we can try to resolve any complaint for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by contacting us via this website.
THIRD PARTY LINKS
- WHAT DATA DO WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual capable of identifying that person. It does not include anonymised data.
We may collect, use, store, transfer and process different types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your home and/or work address (or other physical address), email address and telephone numbers.
- Physical Data may include height, weight, age, gender and dietary preferences.
- Transaction Data may include details about payments between us and other details of products & services (including memberships) purchased from us.
- Technical Data may include your internet protocol (IP) address, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access our website.
- Usage Data may include information about how you use our website, products and services (including memberships).
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
- Video and Photography Data may include photographs and video footage of you using our premises and/or participating in one of our programs. We will not collect, use, store, transfer or process this type of data about you without your explicit consent by way of acceptance of our Video and Photography Consent Form.
- CCTV Data/Footage may be collected in the event that we need to record events at our premises. We do not record at all times, CCTV is activated by senior management only when necessary.
We may collect special category data about you (special category personal data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). In particular, if you inform us as about a medical condition as part of our providing services to you then this will be kept as part of your membership record and used only for ensuring your own wellbeing and safety. We do not collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you (e.g. a membership), and you fail to provide that data when requested, we may not be able to perform the contact we have or are trying to enter with you, especially to provide you with access to our facilities. In this case, we may have to cancel your membership with us but we will notify you if this is the case at the time.
- HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our website (or otherwise) or by communicating with us by post, phone, email or otherwise, or by attending our premises, including when you:
- Join us as a member;
- Order or apply for our products or services;
- your usage of our premises;
- subscribe to our service or publications;
- request resources or marketing communications be sent to you;
- enter a competition, prize draw, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions: As you use our website, we will automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and other similar technologies. The cookies we use are:
- wpSGCacheBypass – this cookie is used by our website hosting provider to improve performance of our website, in particular to cache certain local data.
- cookielawinfo-checkbox-non-necessary – to record and store data on cookie preferences.
- Viewed-cookie-policy – used to record your preferences regarding the information provided on the acceptance our policy on cookies.
- player.vimeo.com – to enable embedded videos to be played on our website. This cookie does not collect your personal data
Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Facebook based outside the EU; and
- search information providers.
Identity, Contact and Transaction Data from providers of technical, payment and delivery services such as GoCardless, Paypal, Stripe or TeamUp.
Identity, Contact Data and Marketing and Communications Data from third party service providers, such as TeamUp or Infusionsoft, should you become a member with us.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Identity, Contact and Physical data from our third party service provide, Simplified Body, to the extent you provide that data via the Simplified Body platform.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract between us; or
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- Where we need to comply with a legal or regulatory obligation; or
- Where we have your express consent to do so.
Where we rely on your consent to use your personal data you have the right to withdraw that consent at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer and create your membership record||(a) Identity (b) Contact (c) Financial (d) Special category, in particular health data.||Performance of a contract with you (save for special category data) Express consent (for special category data only)|
|To process provide services to you and to deliver your order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us; and (c) for booking or attending a class or lesson||(a) Identity (b) Contact (c) Physical (d) Financial (e) Transaction (f) Marketing and Communications||Performance of a contract with you Necessary for our legitimate interests to recover debts owed to us Necessary for our legitimate interests to monitor attendance at classes|
|To manage, review and update your membership choices with us by transferring your data to a CRM system, hosted by TeamUp or other similar organisation to monitor||Identity Contract Profile Usage||Performance of a contract with you Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services|
|To undertake marketing to you of our service, offers and products||(a) Identity (b) Contact (c) Profile (e) Marketing and Communications||Express consent|
|To use Video and Photography Data in our own marketing materials, either to you or others.||Identity Video & Photography Data||Express consent|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||Performance of a contract with you Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business|
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise Necessary to comply with a legal obligation|
|To deliver relevant content and advertisements to you and measure and understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and communications||Necessary for our legitimate interests to develop our products/services and grow our business|
|To respond to a request from you for more information about a product or service (including membership) or contact us with a query or complaint||(a) Identity (b) Contact||Necessary for our legitimate interests to respond to enquiries, queries or complaints|
|If you have an accident or incident in our premises, or where you witness or are personally affected by such an accident||(a) Identity (b) Contact (c) Special category, in particular health data.||Express consent In circumstances where you are unable to give consent, on the basis that it is necessary in order to protect your vital interests or those of another natural person.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you might want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by emailing us at email@example.com.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Client Management Systems, email providers and other third party service providers such as Infusionsoft, TeamUp and/or Simplified Body.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- INTERNATIONAL TRANSFERS
Sometimes we may share your personal data with international software companies such as aweber, dropbox or Xero.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. We urge you to take every precaution to protect your personal data when you are on the internet.
- DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new personal data that you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” (or similar) links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, product/service experience or other transactions.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this privacy notice
This version was last updated on 2 January 2020.