INTRODUCTION
This Privacy Notice explains how we collect and process
personal data about you to provide the services you use; operate our business;
meet our contractual and legal obligations; protect the security of our systems
and our customers; or fulfill our other legitime interest. At Gym X we are
committed to protecting your privacy.
IDENTITY OF DATA CONTROLLER
Gym X. is the data controller for the personal data we
process about you.
Our contact information is:
Gym X at Forest Hill Golf Club Ltd
Markfield Ln, Botcheston,
Leicester LE9 9FH.
If you have any queries about this Privacy Notice, please
contact us at admin@foresthillgolfclub.co.uk
WHEN DO WE COLLECT PERSONAL DATA?
When you sign-up to become a member of Gym X we will know
who you are, and the activities you perform on this Website or undertake at the
gyms that we operate.
We collect your personal data when you:
Visit or browse our website. See our Cookie Policy.
- When
you check in at the Gym
- Ask
us for more information about a product or service, or contact us with
- When
you use the ClubRight and Technogym app.
- A
question or complaint
- Take
part in a competition, prize draw or survey
- Enter
your PIN number or code
- You
have an accident in our gyms or there was an incident where you were a
witness or personally affected
- CCTV
– when you are using our gyms. See below regarding CCTV.
- When
our teams take photos of your attendance at the gym, part of an event or
in a class (Your permission will be asked beforehand)
We may also collect, match or acquire information about you
from other organisations such as Google, Instagram, TikTok and Facebook.
WHAT PERSONAL DATA DO WE COLLECT?
The information we collect about you is required for the
purpose of creating your Member Account and for you to enrol in our gyms. Such
data allows you to be identified as a member of Gym X and includes:
- Name,
date of birth, gender, e-mail address, postal address, telephone number,
health declaration and whether you require disabled access
- Credit
or debit card information, information about your bank account number and
sort code or other banking information. Note that we do not store your
bank or credit card details on our webservers
- Your
usage records and duration of visits, in the form of date, time, gym, and
membership number.
- Your
preferences for particular products or services or interests when you tell
us what they are -- or when we assume what they are, depending on how you
use our products and services
- Your
contact with us, such as a note or recording of a call you make to our
contact centre, an email or other records of any contact you have with us
- Your
membership information -- such as dates of payment owed and received, the
services you use and any other information related to your account
- Marketing
preferences
HOW DO WE USE THE PERSONAL DATA?
We will use your personal data to provide you with the
services, products or information that you have requested, for health and
safety, security and administration purposes, to improve your website
experience, and marketing.
We may need to share your information with our service
providers, associated organisations and agents for these purposes. We may use
your information to:
- Bill
you for using our services as part of your membership
- Keep
you informed about our services including operational matters relating to
your Membership
- To
send you email on abandon basket
- Provide
relevant services to you, e.g. streaks and prompts, or access to Personal
trainers
- To
provide a functional website and to conduct targeted, relevant marketing,
including retargeting via Facebook, Snapchat and Google
- Confirm
your attendance to exercise classes or lessons
- To
allow you to monitor your gym usage in your members area
- To
share gym event photos on our internal social media platform (Your
permission will be asked first before a picture is taken)
- Contact
you (e.g. e-mail, sms) with offers or promotions based on our analysis of
how you use our services and what we think will be of interest to you
(unless you choose not to receive our marketing messages)
- Respond
to any questions or concerns you might have about our services
- Understand
how you use our services, to help us develop relevant and updated services
for your membership, e.g. surveys or other information
- To
use your attendance log to support your membership with relevant
information and services, e.g. loyalty reward, new classes and training
material
- Carry
out research and analysis to understand how customers use our services
- Prevent
and detect fraud or other crimes
- Operate
our facilities in a safe and secure way
BASIS OF LAWFUL PROCESSING
Gym X. relies on the following lawful bases for processing,
storing and retaining your personal data:
In relation to your membership of Gym X:
- your
explicit and freely given consent for the specified purpose of membership
and the use of Gym X's facilities;
- the
processing is necessary for the performance of your membership agreement
with Gym X
- the
processing is necessary for a legal obligation that Gym X is subject to
- the
processing is necessary for the legitimate interest in communicating with
members and conducting customer satisfaction.
In relation to your personal data relating to your health
- your
explicit and freely given consent for the specified purpose of membership
and the use of Gym X's facilities;
- processing
is necessary for reasons of public interest in the area of public health.
- processing
is necessary to protect your vital interests
In relation to website visitors and marketing information
- the
processing is necessary for the legitime interest for Gym X to be able to
provide, optimize and target the website
- the
processing rely on a soft-opt in approach for marketing information
- your
explicit and freely given consent for new openings
- your
explicit and freely given consent for being contacted by a third party,
e.g. Personal trainers
- the
processing is necessary for the legitimate purposes of Gym X or by a third
party to be able to carry out direct marketing
- the
processing is necessary for the legitimate interest to process a limited
amount of data for statistical purposes
In relation to users of the ClubRight and Technogym App
- the
processing is necessary for the performance of an agreement, e.g. class booking
etc.
- the
processing is necessary for the legitim interest in being able to provide
functionality an optimize the App and target ads as well as to communicate
with your via the App
- the
processing is necessary for the legitim interest in providing,
implementing and evaluating class registrations
In relation to your retained data and debt following
termination or cancellation of your membership
- the
processing is necessary for a legal obligation that Gym X is subject to
- the
processing is necessary for the legitim interest in safeguarding the
interest of employees and other members, and commercial interest in being
able to decide when an excluded member can regain membership
RETENTION
We will store you’re personal data for as long as it is
necessary for the purpose of processing.
This mean that we will keep your data for as long as you are
a Member of Gym X. Following cancellation or termination of your membership we
will keep your data if we have a legitim interest and to meet our legal
requirements including health and safety, financial audit, anti-fraud and money
laundering regulations.
We will store your data for no more than 6 years from the
last activity on the account. An ‘activity’ can be classified as access into a
gym, a payment made on the membership account, or a comment added to the
membership following contact with Gym X.
We may contact you about Gym X services during these 6 years
if you haven’t opted out of receiving marketing communications from us. Cookies
and the personal data collected through cookies are deleted in accordance with
our cookie policy.
We will store information until a quarantine period expires
for members excluded from training in Gym X.
CCTV
We process information from CCTV of entrances, reception and
fitness areas as well as training halls. No camera does infringe on sensitive
areas.
This section sets out the appropriate actions and procedures
which Gym X follows in respect of the use of CCTV (closed circuit television)
in our Gyms. Please note that all our gyms are monitored by CCTV 24 hours a
day.
Gym X reserves the right for its employees and contractors
to review footage as required and by entering onto our sites you consent to
your image being recorded and reviewed and waive any and all claims in relation
to same. Recorded CCTV footage will be stored securely and retained in
compliance with applicable laws.
Our CCTV is actively being monitored in unstaffed hours
between 8pm and 8am by our internal CCTV team.
The processing of CCTV will be handled in accordance with
the Data Protection Regulations, The CCTV Code of Practice, and the Human Right
Act 1998.
The purpose of the use of the CCTV Systems and the
collection and processing of CCTV images is for the prevention or detection of
crime or disorder, apprehension, and prosecution of offenders (including use of
images as evidence in criminal proceedings), interest of public and employee
Health and Safety, protection of public health and the protection of our
property and assets and to ensure compliance with our policies and procedures.
Gym Xs processing of CCTV is necessary for the legitim
interest in monitoring the gyms as part of the implementation of security
measures and to be able to exercise or defence a legal claim.
Prior to any camera installation Gym X will ensure that the
installation complies with this policy and that the use of any camera is
justified, necessary and proportionate. Gym X will regularly assess whether the
use of any camera and the CCTV System as a whole continues to be justified,
necessary and proportionate.
The recordings are reviewed by random checks, specific
suspicions, or other irregularities.
All images are digitally recorded and stored securely within
the system’s hard drives. Images are stored for 30 days, unless longer storage
is allowed under legislation.
All access to and disclosure of recorded CCTV images is
restricted and carefully controlled. Access to and disclosure of CCTV is
permitted only if it supports the purpose for which such images have been
collected. Disclosure of CCTV from third parties, e.g. a police enquiry or
investigation, needs to be supported by a DPA- or consent form from the
registered person on the images.
OPT OUT
Gym X will only send you information relating to your
membership and about similar products or services in a digital way, e.g.
e-mail, sms etc. We will not share your data with any third parties for
marketing purposes, unless you consent.
If you cancel your membership with Gym X we will only send
you information that we think will be of interest to you. If you want to opt
out of receiving marketing messages from us, please visit your profile section
within the Members Area of the website. You can choose to opt out of all marketing
or select your marketing preferences. Alternatively you can choose to opt-out
in the footer of all e-mail marketing material received.
If you are no longer a member, and wish to remove your
consent to receive marketing you can access our preference center.
DO WE USE COOKIES?
Gym X uses cookies (small text files stored in your browser)
and other similar technologies, such as web beacons (small, clear picture files
used to follow your online activities) and server-side tagging. These collect
information that tells us how you use our websites, web-related products and
services. The use of cookies does not give us access to the rest of your
computer.
This, in turn, helps us make our website relevant to your
interests and needs. We may use a persistent cookie (a cookie that stays linked
to your browser) to record your details so we can recognise you if you visit
our website again. You can choose to refuse cookies, or set your browser to let
you know each time a website tries to set a cookie. You can find out more information about cookies including
information on how to turn them off.
Please note however that if you disable our cookies you may
not be able to access certain services or facilities on our sites and your use
of our sites may be restricted. This could include joining or logging in to
your members area. See our
cookies policy.
KEEPING YOUR PERSONAL DATA SECURE
We have a dedicated team whose function is to secure our
clients’ data and also take appropriate measures to ensure that the personal
data we collect and maintain is kept secure, accurate and up to date and kept
only for so long as is necessary for the purposes for which it is used.
We ensure the organisations that provide us with services
related to your membership have appropriate security measures and only process
your information in the way we have authorised them to. These organisations
will not be entitled to use your personal data for their own purposes.
Communications over the internet (such as emails) are not
secure unless they have been encrypted. Your communications may go through a
number of countries before being delivered to us – as this is the nature of the
internet. We cannot accept liability or responsibility for any unauthorised
access to or loss of your personal data that is beyond our control.
WILL WE DISCLOSE THE PERSONAL DATA WE COLLECT TO THIRD
PARTIES?
We may share data about you with:
- Service
providers, agents and associated organisations to allow us to service your
membership and communicate with you; for example, financial institutions
to process payments, and freelance personal trainers when you sign up to
classes
- Law
enforcement agencies, regulatory organisations, courts or other public
authorities where we have a legal obligation to do so
- If
you joined via one of our corporate partners, for example Vitality, we may
share your membership information with that corporate partner for the
purposes of managing the relevant membership scheme.
We will release information if it is reasonable for the
purpose of protecting us against fraud, defending our rights or property, or to
protect the interests of our customers.
If we are reorganised or sold to another organisation, we
may transfer any personal data we hold about you to that organisation. We will
inform you if we do.
USE OF PERSONAL DATA FOR AUTOMATIC DECISION MAKING
We do not intend to use your personal data for automatic
decision making.
THIRD PARTY TRACKING
We use tools such as Google Analytics for collecting
personal data about our website visitor’s online activities over time and
across different web sites for marketing purposes. This is so we can ensure our
website gives you the best possible experience. For more information and how to
opt out from this please visit our cookies policy.
DO NOT TRACK (DNT)
The Gym X website does not respond to DNT signals.
COLLECTION OF CHILDREN'S DATA
At Gym X, we are committed to safeguarding the privacy of
children who access our gym and its services. This policy also explains how we
collect, use, and protect personal information about children under the age of
18.
We collect personal information about children to:
- Provide
a safe and effective gym experience.
- Communicate
with parents/guardians and manage memberships.
- Comply
with legal requirements and health and safety regulations.
We use children’s personal data for:
- Registering
gym memberships and maintaining records.
- Ensuring
the safety and wellbeing of children during gym activities.
- Contacting
parents/guardians about gym-related updates or emergencies.
We only collect data that is necessary for providing our
services.
We process children’s data based on the following legal
bases:
- Consent:
We require the consent of a parent or guardian for any child under 18.
- Contractual
Necessity: To provide gym membership services.
- Legal
Obligations: To comply with health and safety laws.
We require parental or guardian consent for any child under
16 before collecting or processing their data.
Under data protection laws, children and their
parents/guardians have the following rights as mentioned below.
YOUR PRIVACY RIGHTS
Below we have prepared an overview of your rights. Please
note that there may be conditions or restrictions attached to exercise the
rights below. It is therefore not certain that you, for example, have the right
to deletion in specific cases. If you wish to exercise one or more of the below
rights, please contact us by writing an email to admin@foresthillgolfclub.co.uk
with information on your name and membership number to verify your
identification. Access. You have the right to ask for a copy of the data we
hold about you.There is not normally a fee for this service.
Rectification. If you believe we are holding
inaccurate information about you, or your personal details change, please
update your profile on the Gym X website in the members’ area. Debit, Credit
and Bank account changes can be made in your members’ area on the Gym X
website.
Erasure. You have the right to erasure of the
data we hold on you, when it is no longer needed for the purposes of your
Membership, or when you withdraw your consent for our processing (and we have
no other lawful basis to hold your data).
Restriction. You have the right to ask us to
place restrictions on processing your data in certain circumstances.
Notification. You have the right to be notified
of any rectification, erasure or restrictions in relation to your personal
data.
Portability. You have a right to receive the
data we hold on you electronically in a format that allows it to be easily
transferred to another data controller.
Object. You have the right to object to data
processing of your personal data for direct marketing or profiling purposes.
Withdraw. If Gym X rely on consent, you have the
right to withdraw your consent for the specific processing.
Profiling. You have the right not to be subject
to any decision based on automatic processing of your personal data.
If you want to complain, alternatively, you can contact the
Information Commissioner’s Office at https://ico.org.uk/concerns/.
CHANGES TO THIS PRIVACY NOTICE
We will update this Privacy Notice over time, especially if we change our data processing activities or if new legal requirements become applicable.