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Privacy Notice - 16th September 2021

INTRODUCTION

At PureGym we are committed to protecting your privacy.

We collect and process personal data about you in order 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 fulfil our other legitimate interests.

This Privacy Notice explains how we collect, use, share and protect your personal information. When we update this Privacy Notice we will post any changes on our website.

In addition when visiting our website, we will provide you with “just in time” notices at the moment of data collection.

If you have any queries about this Privacy Notice please contact us at PureGym Ltd, 4th Floor, Town Centre House, Merrion Centre, Leeds, LS2 8LY. Alternatively send an email to datarequest@puregym.com.

IDENTITY OF DATA CONTROLLER

PureGym Ltd. is registered with the Information Commissioner’s Office (the ‘ICO’) as a data controller under registration reference Z3465837.

The ICO is the United Kingdom’s independent Regulatory Authority in relation to data protection and information rights. The ICO provides a helpline and complaints service and can be contacted at:

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or at www.ico.org.uk or by telephone on 0303 1231113.


WHEN DO WE COLLECT INFORMATION?

We collect your personal information when you:

  • Complete an Online Membership Agreement
  • Register your interest for upcoming PureGym opening locations
  • Ask us for more information about a product or service, or contact us with a question or complaint
  • Take part in a competition, prize draw or survey
  • Visit or browse our website. See our Cookie Policy.
  • Contact our Member Services support team through telephone, email or online chat
  • Send an email to an @puregym.com email account
  • Enter your PIN number or swipe your fob into one of our gyms
  • You have an accident in our gyms or there was an incident where you were a witness or personally affected
  • When you use equipment in the gym such as Hydro Massage or when you obtain a drink from one of the Yanga Water stations
  • When you book classes, courses and inductions
  • CCTV – when you are using our gyms. See our CCTV policy.
  • When you use the PureGym app
  • 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)

When using our gyms CCTV is being recorded 24 hours a day and actively monitored between 8pm and 8am by our internal CCTV team. CCTV is permanently erased after 31 days.

We may also collect, match or acquire information about you from other organisations such as Google and Facebook.


WHAT INFORMATION 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 information allows you to be identified as a member of PureGym 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 web servers

  • Your usage records and duration of visits

  • 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


HOW DO WE USE THIS INFORMATION?

We will use your personal information 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:

  • Carry out an identity check as part of your membership application. This is carried out by Bottomline Technologies Ltd and is NOT a credit check
  • Process your membership application through Exerp, our chosen membership software
  • Bill you for using our services as part of your membership
  • Keep you informed about our services including operational matters relating to your Membership
  • Provide relevant services to you
  • 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 called workplace (Your permission will be asked first before a picture is taken)
  • Contact you 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
  • Carry out research and statistical analysis to monitor how customers use our services
  • Prevent and detect fraud or other crimes
  • Operate our facilities in a safe and secure way
  • Covid-19 Track & Trace - To prevent the spread of infection around the UK we will support the NHS Track & Trace system. If requested by the NHS to provide visitor information, due to an outbreak in the vicinity of one of our gyms, we will supply your name, mobile and time of arrival and departure for members who had recently visited the specific site. This is voluntary and you are able to request to have your data excluded. Please email us at trackandtrace@puregym.com with you name and PIN number and we will not pass your details on.

We will store your information for as long as you are a Member of PureGym, or following cancellation of your membership and to meet our legal requirements including health and safety, financial audit, anti-fraud and money laundering regulations. We will store your information 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 PureGym. We may contact you about PureGym services during this 6 years if you haven’t opted out of receiving marketing communications from us.


BASIS OF LAWFUL PROCESSING

PureGym Ltd. relies on the following lawful bases for processing, storing and retaining your personal data:

  1. In relation to your membership of PureGym:
    1. your explicit and freely given consent for the specified purpose of membership and the use of PureGym’s facilities;
    2. the processing is necessary for the performance of your membership contract with PureGym
    3. the processing is necessary for a legal obligation that Puregym is subject to
    4. the processing is necessary for the legitimate purposes of PureGym or by a third party
  2. In relation to your personal data relating to your health
    1. your explicit and freely given consent for the specified purpose of membership and the use of PureGym’s facilities;
    2. processing is necessary for reasons of public interest in the area of public health including the cross border threats posed by Covid 19
    3. processing is necessary to protect your vital interests
  3. In relation to your retained data following termination of your membership
    1. the processing is necessary for a legal obligation that PureGym is subject to
  4. In relation to marketing information
    1. the processing is necessary for the legitimate purposes of PureGym or by a third party

OPT OUT

PureGym will only send you information relating to your membership. We will not share your data with any third parties for marketing purposes, unless you consent. If you cancel your membership with PureGym 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, if you are no longer a member, and wish to remove your consent to receive marketing please contact by email to datarequest@puregym.com.


DO WE USE COOKIES?

PureGym 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 INFORMATION SECURE

We have a dedicated team whose function is to secure our clients’ information and also take appropriate measures to ensure that the information 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 information 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 information that is beyond our control.


WILL WE DISCLOSE THE INFORMATION WE COLLECT TO OUTSIDE PARTIES?

We may share information 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
  • Covid-19 Track & Trace - To prevent the spread of infection around the UK we will support the NHS Track & Trace system. If requested by the NHS to provide visitor information, due to an outbreak in the vicinity of one of our gyms, we will supply your name, mobile and time of arrival and departure for members who had recently visited the specific site. This is voluntary and you are able to request to have your data excluded. Please email us at trackandtrace@puregym.com with you name and PIN number and we will not pass your details on

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 information 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 PureGym website does not respond to DNT signals.


COLLECTION OF CHILDREN'S DATA

PureGym does not collect or process the personal data of children under the age of 16.


YOUR PRIVACY RIGHTS

You have the following rights in relation to your data privacy: the right of access; the right of rectification; the right of erasure (the “right to be forgotten”); the right to restriction of processing; the right to be notified; the right to data portability; the right of objection; and the right to not be subject to automated profiling.

Access.  You have the right to ask for a copy of the information we hold about you and to have any inaccuracies in your information corrected. Please contact us through email to datarequest@puregym.com, the contact us section of the website or writing to the address below. 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 PureGym website in the members’ area. Debit, Credit and Bank account changes can be made in your members’ area on the PureGym website.

Erasure. You have the right to the 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.

Profiling.  You have the right not to be subject to any decision based on automatic processing of your personal data.

The address to be used to obtain a copy of your personal information is: PureGym Ltd, 4th Floor, Town Centre House, Merrion Centre, Leeds, LS2 8LY. You can also contact us by emailing datarequest@puregym.com


GOVERNMENT TRACK AND TRACE

To prevent the spread of infection around the UK we will support the NHS Track & Trace system. If requested by the NHS to provide visitor information, due to an outbreak in the vicinity of one of our gyms, we will supply your name, mobile and time of arrival and departure for members who had recently visited the specific site. This is voluntary and you are able to request to have your data excluded. Please email us at trackandtrace@puregym.com with you name and PIN number and we will not pass your details on.


CHANGES TO THIS PRIVACY NOTICE

We will update this privacy notice to reflect the way in which we process and protect your data. If we do so, we will post notice of the change on our website and you will have the opportunity to adjust your communications preferences via your Member Profile within the Members Area of the website.

Date of last revision 16th September 2021