Privacy Policy - Welcome Gym

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Privacy Policy


Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies, Usage Data, email address, first name, last name, phone number, gender, date of birth, profession, address, postal code and bank details.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact Welcome Gym.

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Mode and place of processing the Data

Methods of processing
Welcome Gym takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. The Data may be accessible to certain types of persons in charge of the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Welcome Gym. The updated list of these parties may be requested from the Welcome Gym at any time.

Legal basis of processing
Welcome Gym may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes.
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which Welcome Gym is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Welcome Gym;
• processing is necessary for the purposes of the legitimate interests pursued by the Welcome Gym or by a third party.

In any case, Welcome Gym will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place
The Data is processed by Welcome Gym at our clubs and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Welcome Gym to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with Welcome Gym using the information provided in the contact section.

Retention time
Personal Data shall be processed and stored for as long as required for the purpose they have been collected for.

Therefore:
• Personal Data collected for purposes related to the performance of a contract between Welcome Gym and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of Welcome Gym’s legitimate interests shall be retained as long as needed to fulfil such purposes.

Users may find specific information regarding the legitimate interests pursued by Welcome Gym within the relevant sections of this document or by contacting Welcome Gym.

Welcome Gym may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Welcome Gym may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow Welcome Gym to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Content commenting, Handling payments, Remarketing and behavioural targeting, displaying content from external platforms and Managing contacts and sending messages.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Selling goods and services online
The Personal Data collected are used to provide the User with services and process payments.

The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Website depends on the payment system used.

Handling payments
Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Sage Pay (Sage Pay Europe Limited) Sage Pay is a payment service provided by Sage Pay Europe Limited. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United Kingdom

Contacting the User

Contact form (this Website)
By filling in the contact form with their Data, the User authorises this Website to use these details to reply to requests for information or any other kind of request as indicated by the form’s header. Personal Data collected: address, date of birth, email address, first name, gender, last name, phone number, profession and Postal code.

Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Welcome Gym. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase. Personal Data collected: email address, first name, last name and phone number.

Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailgun (Mailgun, Inc.) Mailgun is an email address management and message sending service provided by Mailgun, Inc. Personal Data collected: email address. Place of processing: United States

Messagebird (MessageBird B.V.) Messagebird is a SMS management and message sending service provided by  Personal Data collected: mobile number. Place of processing: The Netherlands

Telecommunication TSG is a UK based telecommunications management service who in exceptional circumstances will contact members and recently expired members to evaluate the performance of the membership agreement on behalf of Welcome Gym for our research purposes.

Analytics

The services contained in this section enable Welcome Gym to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: United States

Facebook Ads conversion tracking (Facebook, Inc.) Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website.
Personal Data collected: Cookies and Usage Data. Place of processing: United States

Facebook Analytics for Apps (Facebook, Inc.) Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service. Place of processing: United States

Google AdWords conversion tracking (Google Inc.) Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Website. Personal Data collected: Cookies and Usage Data. Place of processing: United States

Twitter Ads conversion tracking (Twitter, Inc.) Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Website. Personal Data collected: Cookies and Usage Data. Place of processing: United States

Content Commenting
Content commenting services allow Users to make and publish their comments on the contents of this Website.

If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Facebook Comments (Facebook, Inc.) Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform. Personal Data collected: Cookies and Usage Data. Place of processing: United States

Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Maps widget (Google Inc.) Google Maps is a maps visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data. Place of processing: United States

CCTV policy
Welcome Gym uses CCTV for maintaining the security of the premises and for crime prevention purposes and the protection of our customers and staff. Please note that our gyms are monitored by CCTV 24 hours a day. Welcome Gym Group Limited reserves the right for its employees and contractors to review footage as required and by entering onto our sites you agree to your image being recorded and reviewed. Recorded CCTV footage will be stored securely.

Biometrics
Welcome Gym uses Biometrics for entry to all our gyms. A very low-resolution collagen record of the member's fingerprint is converted from analogue to digital form. All biometrics data is stored securely and is deleted as soon as a membership expires.

The rights of Users

Users may exercise certain rights regarding their Data processed by Welcome Gym.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with Welcome Gym to find out which rights apply to them.

In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by Welcome Gym, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Welcome Gym will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to make a complaint to the Information Commissioners Office.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Welcome Gym or for the purposes of the legitimate interests pursued by the Welcome Gym, Users may object to such processing by providing grounds related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether Welcome Gym is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to Welcome Gym through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Welcome Gym as early as possible and always within one month.

Additional information about Data collection and processing

Legal action
The User's Personal Data may be used for legal purposes by Welcome Gym in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that Welcome Gym may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from Welcome Gym at any time. Please see the contact information at the bottom of this document.

Changes to this privacy policy

Welcome Gym reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to Welcome Gym. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, Welcome Gym shall collect new consent from the User, where required.

How to Contact Us

If you have any questions about our Privacy Policy, please contact us at: The Fitness Trust, c/o Welcome Gym, Amersham Road, Chesham, HP5 1NE or on info@welcomegym.co.uk


Policy Updated: 23rd May 2018