1. General intro
1.1. We are committed to ensuring that we manage your personal data professionally and in compliance with all applicable data protection laws. Part of this commitment is to ensure that there is transparency about how we process personal data.
This policy includes an explanation of:
1.1.1. what data we are processing;
1.1.2. why we are processing it and what we do with it;
1.1.3. whether we will share it with anyone else;
1.1.4. whether we will transfer it outside of the European Economic Area (EEA);
1.1.5. how we keep your data safe; and
1.1.6. your rights.
1.2. We hope that you find this Data Protection Policy helpful. If you have any questions, please don’t hesitate to contact us.
2. Who we are and our contact details
2.1. We are FITNESS IN TIME LTD and our registered office is at. We are incorporated in England and Wales and our company number is 06418535. In this Data Protection Policy FITNESS IN TIME LTD is referred to as we, us, our or FIT.
2.2. Please send any queries concerning your data to us using the following contact details:
Name: Compliance Officer (Data Protection)
Email address: firstname.lastname@example.org
3. Your personal data
3.2.1. We have obtained information about you when you have enquired about membership or had a treatment at a Fitness In Time health club. Typically, the information that we obtain will be your name, address, email address, phone number, payment information and a photograph of you.
3.2.2. If you have visited our website we may automatically collect some personal information including details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and the Internet protocol (IP) address assigned to you by your internet service. We collect some of this information using cookies – please see Cookies in section 4 for further information. We may also collect any personal information which you allow to be shared or that is part of your public profile on a third party social network.
3.2.3. Our telephone calls may be recorded for training purposes and may also be used to verify any comments that were made during any conversation.
3.2.4. Some Fitness In Time clubs may have CCTV in operation. This is for security as well as health and safety purposes. It is, therefore, possible that images of you will be recorded when visiting our sites.
3.2.5. Your photograph will be used to ensure that you can access Fitness In Time health clubs.
3.3. How do we use your personal data and what is the applicable lawful basis?
3.3.1. Where you have consented, we may provide you with marketing information about our products and services, the products and services offered by FIT or our franchisees and the products and services of selected partners. In addition, we will keep you informed of events that we think will be of interest to you.
3.3.2. We may process your information to ensure that you are provided with all the benefits of your membership of a FIT health club.
3.3.3. We may process your information to comply with our legal obligations.
3.3.4. We may process your information to allow us to pursue our legitimate interests including:
126.96.36.199. Analysing our performance and the performance of our clubs in delivering services and products to you;
188.8.131.52. Market research, training and the administration of our website;
184.108.40.206. The prevention of fraud or other criminal acts;
220.127.116.11. Undertaking credit checks for finance;
18.104.22.168. Complying with requests from you including if you exercise any of your rights noted in this Data Protection Policy;
22.214.171.124. The purpose of corporate restructure or reorganisation or sale of our business or assets;
126.96.36.199. Enforcing our legal rights or to defend legal proceedings and for general administration purposes.
3.4. Will we share your personal data with any third parties?
3.4.1. We may share your personal data with FIT, the owner of the FIT health club at which you are a member and, if you visit another FIT health club, the operator of that health club.
3.4.2. We may disclose your information to third-party service providers for the purposes of providing services to us or directly to you on our behalf. When we use third-party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
3.4.3. If the owner or franchisee of the FIT health club at which you are a member sells its business to a third party, we may transfer your information to that third party to ensure that it can continue to provide you with the services that you expect to receive as a member of a FIT health club.
3.4.4. We may transfer your data to government or other official bodies for the purposes of complying with legal obligations, for enforcing our rights, or for the prevention or detection of a crime.
3.5. How long do we keep your data?
3.5.1. If you have expressed an interest in buying FIT products or services or other products and services from our selected partners, we will retain your contact details and related information concerning your enquiry for [five] years from the date that we last had contact with you.
3.5.2. If you have purchased membership of a FIT health club, if you have purchased FIT goods or services or if you have purchased goods or services from our selected partners, we will keep the data relating specifically to that purchase (e.g. order forms, invoices and related correspondence) for seven years from the date of the contract.
3.5.3. Voice recordings of telephone calls, CCTV images and data related to your use of courtesy vehicles shall be kept for a maximum of 6 months unless we have a good reason to retain such information for a longer period. This might be because of a contractual dispute or an injury suffered by you or another person.
3.5.4. If you have requested that we do not send you marketing information we will always retain sufficient information to ensure that we remember to comply with your request.
3.5.5. All of the periods stated in this section may be extended if there is a legal requirement to do so.
3.6. Transferring your data outside of the European Economic Area (‘EEA’)
3.6.1. The information that you send to us may be transferred to countries outside the European Economic Area (EEA) including the USA. By way of example, FIT may view information stored on the information systems that FIT and its franchisees are required to use as part of the FIT system and your information may also be transferred out of the EEA or if any of our servers or those of our third-party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK.
3.6.2. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected. These measures include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact [the DPO whose contact details are set out above] if you would like more information about the protections that we put in place.
3.6.3. If you take advantage of the benefits of membership of a FIT health club outside the EEA, your information may be transferred outside the EEA to provide you with those services.
4.2. You can find out more about the cookies we use in our Cookies Policy.
4.3. You can set your browser not to accept cookies, however, some of our website features may not function as a result.
4.4. For more information about cookies generally and how to disable them you can visit: www.allaboutcookies.org
5. Data security
5.1. We have adopted the technical and organisational measures necessary to ensure the security of the personal data we collect, use and maintain, and prevent their alteration, loss, unauthorised processing or access, having regard to the state of the art, the nature of the data stored and the risks to which they are exposed by human action or physical or natural environment. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database.
5.2. Unfortunately, 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 information, we will use procedures and security features to try to prevent unauthorised access.
5.3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
6. Links to other websites
7. Social Plugins
7.1. We use so-called social plugins (buttons) of social networks such as Facebook, Google+ and Twitter.
7.3. After their activation, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website.
7.4. After activation of a button, the social network can retrieve data, independently of whether you interact with the button or not. If you are logged on to a social network, the network can assign your visit to the website to your user account.
7.5. If you are a member of a social network and do not wish it to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network concerned before activating the buttons.
7.6. We have no influence on the scope of data that is collected by the social networks through their buttons. The data use policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.
8. Your rights
8.1. Your right to access data
8.1.1. We always aim to be as open as we can and allow people access to their personal information. Where we hold your personal data, you can make a ‘subject access request’ to us and we will provide you with:
188.8.131.52. a description of it;
184.108.40.206. an explanation of why we are holding it;
220.127.116.11. information about who it could be disclosed to; and
18.104.22.168. a copy of the information – unless an exception to the disclosure requirements is applicable.
8.1.2. If you would like to make a ‘subject access request’ please make it in writing to [the DPO whose contact details are set out above] and mark it clearly as ‘Subject Access Request’.
8.1.3. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
8.1.4. Unless you agree to a different time, we will complete your subject access request within one month.
8.2. Right to stop marketing messages
You always have the right to stop marketing messages. We will usually include an unsubscribe button in any marketing emails. If you do wish to unsubscribe, please just click the unsubscribe button and we will promptly action that request. Alternatively, you can update your marketing preferences by contacting us at FIT.
8.3. Right to be forgotten
If we hold personal data about you, but it is no longer necessary for the purposes that it was collected and cannot otherwise be justified, you have the right to request that we delete the data.
8.4. Right to restrict data
If we hold personal data about you and you believe it is inaccurate you have the right to request us to restrict the data until it is verified. You also have the right to request that the data is restricted where you have a right to it being deleted but would prefer that it is restricted.
8.5. Transferring your personal data
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under section 3, you may ask us to provide you with a copy of that information in a structured data file to you or to another service provider. We will action this request, usually by sending the data in a CSV file.
8.6. Right to complain
You always have the right to complain to the personal data regulator, the ICO. You may also be entitled to seek compensation if there has been a breach of data protection laws.
9. Policy updates
This policy was last updated on 15th June 2018.