Updated 11 / 07 / 2020
If you have any comments, queries or concerns about how we collect and use your personal information, or if you wish to exercise your rights or make a complaint, please contact us at firstname.lastname@example.org
Your Privacy Rights
You have certain rights in respect of the personal information that we process about you. You have the right to object to how we use your personal information. You also have the right to see what personal information we hold about you. In addition, you can ask us to correct inaccuracies, delete or restrict personal information or to ask for some of your personal information to be provided to someone else. To make enquires for further information about exercising any of your rights in this Privacy Notice, please contact us using the details above.
You can make a complaint to us about how we handle your personal information by contacting us at the details above, or by contacting the UK data protection supervisory authority, the ICO, at https://ico.org.uk/
You are entitled to exercise any of the following privacy rights:
- Right to object: You can object to our processing of your personal information. Please contact us as noted below, providing details of your objection.
- Access to your personal information: You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge by contacting us as noted below.
- Right to withdraw consent: If you have given us your consent to use your personal information, for example, consent to use your health information or consent to send you marketing emails, you can withdraw your consent at any time by contacting us using the details above.
- Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
- Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
- Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
- Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
- Make a complaint: You can make a complaint about how we have used your personal information to us by contacting us as noted below, or to a supervisory authority – for the UK this is the ICO, at https://ico.org.uk/.
Please make all requests to exercise your privacy rights in writing to us at the details above. We are required to verify your identity in order to process your request and may ask you to provide valid identification documents to allow us to do so.
We will not make any charge for responding to any request from you to exercise your privacy rights, and we will respond to your requests in accordance with our obligations under data protection law.
WHAT PERSONAL INFORMATION IS COLLECTED AND USED?
We may collect and use your personal information when you sign up to become a member of our Gym, if you are a guest of a member visiting our Gym, or if you make an enquiry or a complaint to us.
We collect and use personal information such as names, date of birth, contact details and payment information (such as bank account or credit card details. If you are a member of our gym, we will also collect and process certain health information which is collected when you complete a Physical Activity Readiness Questionnaire (PARQ).
We may collect and process the following information about you:
- Members: When you apply to become a member of our Gym, we will collect certain personal information as set out in our application form and the PARQ. This will include your name, contact details, photograph, payment information (such as bank account or credit card details), information about your fitness goals and aspirations, information about your diet, and some health information (for example, about any pre-existing medical conditions that you may have). We will seek your consent to collect and use this information as part of the PARQ. Please note that if you refuse to provide this consent or if you withdraw your consent, we may not be able to offer you certain services. More information about this can be found on the PARQ or you can contact us at the details above.
- Guest: Where you are using our facilities as a guest of a member, we may still be required to collect personal information such as your name and contact details.
- Complaint / Enquiry: If you make a complaint or enquiry about our services, we will collect and use your name, contact details and information about the nature of your complaint or enquiry.
- CCTV: We use CCTV at our Gym and this will record footage of you while you are at our Gym.
- Identification: Where you are using our facilities (as either a member or a guest of a member), we may collect and use personal information to verify your identity and age, such as a copy of your passport or driving licence.
- Surveys: We may collect personal information about you where you decide to complete a survey about our services.
HOW IS PERSONAL INFORMATION COLLECTED OR GATHERED?
We only use personal information which we have obtained directly for the purposes described in this Policy.
We will collect the personal information that we use about you directly from you, for example when you complete a form (such as a membership application form or a PARQ). We will also collect footage of you at our facilities from our CCTV system.
We do not collect information about you from third parties, or supplement the information you provide to us with information from third parties.
WHAT IS PERSONAL INFORMATION USED FOR?
We will use your information for the following purposes:
- to provide you with services which you have requested from us in connection with your membership with us or as a guest user, such as processing class bookings, booking personal trainer sessions, or developing a tailored training programme for you;
- we will use payment information to process your payments to us for the services that we provide under our contract with you;
- where you have consented to receive direct marketing from us, we will use your contact information to send you information about our services, promotions and news;
- we operate CCTV systems at our premises for the purposes of the prevention and detection of crime at our facilities;
- we may process identity verification information to check your identity before processing your application or before allowing you access to our facilities; and
- we may process technical information gathered from cookies when you visit our website to improve the functionality of our website. Further information on cookies is available below.
WHAT IS THE LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION?
We only use your personal information where that is permitted by the laws that protect your privacy rights.
We only use personal information where:
- we have your consent (if consent is needed), for example your consent to use your health information and to send you marketing emails;
- we need to use the information to comply with our legal obligations;
- we need to use the information to perform a contract with you (for example, where your membership contract); and/or
- it is fair to use the personal information either in our interests or someone else’s interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services.
Where we have your consent to process your personal information, you have the right to withdraw your consent at any time. You can do this by contacting us at the details noted above.
Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations.
We will collect and use health information when you complete a PARQ. We use this information to ensure that any tailored services we provide to you take into account your health and any pre-existing medical conditions. We will ask for your consent to use this information when you complete a PARQ.
IS PERSONAL INFORMATION SHARED WITH THIRD PARTIES?
We will share personal information with relevant third parties where:
- we need to do so for the purposes of providing you with the services you have requested from us (for example, we need to share your personal information with your personal trainer where you have requested personal trainer services);
- it is necessary to allow us to meet or enforce a legal obligation (for example, we may need to share CCTV footage or you with the police); or
- it is fair and reasonable for us to do so in the circumstances. For example, we may share personal information on a confidential basis with any third party that may acquire all or part of our business.
We will only share your personal information with third parties to the extent needed for those purposes.
We will also share your personal information with our sub-contractors where it is necessary to do so.
We may share your personal information with the following sub-contractors and suppliers:
- Personal Trainers: Where you have requested personal trainer services as part of your membership, we will need to share your information with your allocated personal trainer. Please note all personal trainers that work from our facilities are self-employed individual contractors, who may use your information for other purposes without our knowledge. If you have any concerns or queries about how your personal trainer uses your information, you should contact them directly.
- IT Suppliers: Information may be stored and processed on systems provided and supported by our third party IT suppliers.
- Payment processors: Information may be passed to third party payment processors when you make a payment to us online.
- Marketing: we may use third parties to help us prepare and send out marketing communications. Where you have consented to receive marketing communications, we may pass your information to these third parties
IS PERSONAL INFORMATION TRANSFERRED OUTSIDE THE UK?
We may need to transfer your information outside the UK to service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the European Economic Area (EEA), such as the USA. Please click here for more information.
We may need to transfer your personal information to territories that are outside the EEA. We will only transfer your personal information outside the EEA where either:
- the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal information, or
- we have put in place our own measures to ensure adequate security as required by data protection law. These measures include ensuring that your personal information is kept safe by carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses. Some US providers may also be certified under the EU-US Privacy Shield which confirms they have appropriate measures in place to ensure the protection of your data.
HOW LONG IS PERSONAL INFORMATION KEPT FOR?
We will never retain your personal information for any longer than is necessary for the purposes we need to use it for.
- Where you are a member with us, we will retain information collected in connection with your membership for as long as you are a member with us, and for up to 6 years after the end of your membership with us.
- Where you are visiting our facilities as a guest of a member, we will retain your information for up to 6 months after your visit.
- If you are not a member but you make an enquiry or complaint about our facilities, we may retain information in connection with your complaint or enquiry for up to 1 year after the resolution of your enquiry or complaint.
- Where we have been using your personal information to provide you with marketing emails, we will retain this information for as long as you continue to agree to receive these communications, and we will delete your personal information following your request to be removed from our marketing email list.
- We retain CCTV footage for a period of 30 days before it is securely destroyed.
- We may hold your personal information for longer where it is necessary to do so for the management of any active or potential legal proceedings, to resolve or defend claims, and for the purpose of making any necessary remediation payments.
YOUR ONLINE ACTIVITIES
A cookie is a small file which is sent to your browser and stored on your computer’s hard disc. Cookies help us understand and track your use of our website and where we can improve the information and services provided.
We use the following categories of cookies on our website:
- Strictly necessary: These cookies are essential for certain features of our websites to work (for example, when you make payments for car parking). These cookies do not record identifiable personal information and we do not need your consent to place these cookies on your device. Without these cookies some services you have asked for cannot be provided.
- Performance: These cookies are used to collect anonymous information about how you use our websites. This information is used to help us improve our websites and understand how effective our adverts are. In some cases we use trusted third parties to collect this information for us but they only use the information for the purposes explained.
- Functionality: These cookies are used to provide services or remember settings to enhance your visit for example text size or other preferences. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites.
- Targeting and Advertising: These cookies are used by trusted third parties to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. Information contained in these cookies is anonymous and doesn’t contain your personal information. To find out more about cookies used for targeting and advertising follow www.youronlinechoices.com and www.networkadvertising.org or contact us for further information about the trusted third parties we use.
- Managing our cookies: If you would prefer to restrict, block or delete cookies from EAL and our third party advertisers, or any other website, you can use your browser to do this. Each browser is different, so check the “Help” menu of your particular browser to learn how to change your cookie preferences. If you choose to disable all cookies we cannot guarantee the performance of our websites and some features may not work as expected
- Keeping you up to date
We will use the contact details which you have provided to us to communicate relevant news and information about our services to you by email, post, text message, social media, and notifications on our app or website.
Where you have given us consent to receive marketing, you can withdraw consent at any time by clicking the “unsubscribe” link in any marketing email or communication which you receive.