GDPR: DATA PRIVACY NOTICE FOR CLIENTS
YourStyle Fitness Ltd (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Who are we?
YourStyle Fitness Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: email@example.com or 07552554528. For all data matters contact our data protection officer on firstname.lastname@example.org or 07552554528.
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
Personal Data that Yourstyle Fitness holds on Free Trial Clients and Third Party Software Systems
YourStyle Fitness Ltd holds on our electronic database a trial clients full name, email and phone number which has been provided by the client when they opt in to request a free trial via a Client Central Leadpage; by contacting the studio directly or by booking classes via a third party API integration of Mindbody. Trials will opt in themselves in via the Client Central system or be added manually to Client Central by the member staff dealing with the direct enquiry or third party booking. Once a chosen class is booked for a free trial the clients name, email and phone number are transferred into Mindbody to confirm the booking. Third Party bookings are automatically booked directly onto Mindbody via the API integration.
On attendance of a trial the client will be requested to complete a medical waiver form prior to class that informs YourStyle Fitness Ltd of your consent that you are medically fit to partake in classes. Upon this form we also request emergency contact details of a name and phone number and relation should the need ever arise. We also request birth date to ensure we cater to the clients individual needs during class. This information is kept in a locked cabinet for 3 years.
Any participants between the ages of 13 – 17 inclusive will not have personal data stored on Client Central when opting in for a trial class. Should anyone of this age range apply their data will be removed from Client Central. The only data that will remain on file is the medical waiver completed prior to the trial class, which is held in a locked cabinet for 3 years.
Personal Data that Yourstyle Fitness Ltd holds on Paying Clients
If deciding to join Yourstyle Fitness Ltd the client will finalise the medical waiver form and input their Name on Account, Billing Address and Sort Code and Account Number which is locked in a cabinet for 3 years and inputted on our Mindbody electronically encrypted system that utilise’s PaySafe as a payment processor. Credit card data may also be stored dependant on client individual purchases and preferences. This is to purchase credits and allow booking for classes via the Mindbody app and online system depending on individual preferences and will be held on the system for six years for tax purposes.
YourStyle Fitness Ltd clients can partake in a nutritional screening to which they will provide a Name, Email and Phone and any allergies or medical conditions that we should be aware of when providing advice. This data is required in order for YourStyle Fitness Ltd to identify who is partaking in the survey and support correctly. The system utilised for the Nutritional Screenings is Survey Monkey and the data is inputted directly by the client and deleted after 3 years.
Any participants between the ages of 13 – 17 inclusive will only be allowed to join YourStyle Fitness Ltd on a joint account with a consenting parent or guardian. Should classes be attended separately then a consent form must be signed by the parent or guardian and kept on file with the medical waiver in the locked cabinet. A Mindbody account will be created for the individual in order to book classes and log in via the app inclusive of name, email and phone number.
- The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data: Full Name, Email, Phone Number, Address, Birth Date, Bank Details, Emergency Contact Name and Phone Number
- Special categories of data: Pre -existing or Current Medical Conditions
We have obtained your personal data from opting in for a Free Trial or as an enquiry via our website, Facebook, Instagram, Twitter, at events we have attended, via Joint Ventures or flyers distributed within the community.
Special Categories of data have been collected via the medical waiver prior to the first class attended.
- What is our legal basis for processing your personal data?
- Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
|☐ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract||Full Name, Email, Phone, Address, Bank Details are all required to allow booking and payment of classes.|
- Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
|☐ Processing necessary for the reasons of public interest in the area of public health
|Medical Waiver inclusive of Birth date and emergency contact details (Name and Phone number) completed in order to understand whether an individual is safe to exercise or whether consent is required by a medical professional.|
More information on lawful processing can be found on the ICO website.
- Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with Mindbody in order to create a booking account for classes. Paysafe in order to take payments. Client Central when opting in for trials and communications.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 3 years in case of any legal claims/complaints.
- Providing us with your personal data
We require your personal data as it is a requirement to book into classes and necessary to enter into a contract.
- Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data.
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
- Transfer of Data Abroad
We do not transfer personal data outside the EEA.
- Automated Decision Making
We do not use any form of automated decision making in our business for clients.
- Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
- How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our data protection officer on email@example.com or 07552554528.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.