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 LA18 Fitness we are committed to protecting your privacy.
IDENTITY OF DATA CONTROLLER
LA18 Fitness Ltd. is the data
controller for the personal data we process about you.
Our contact information is:
LA18 Fitness Limited. Market
Street, Millom, Cumbria. LA18 4AH.
If you have any queries about
this Privacy Notice, please contact us at info@la18fit.com
LA18FitnessLtd. is registered
with the Information Commissioner’s Office (the ‘ICO’) as a data controller
under registration reference ZB935384.
WHEN DO WE COLLECT PERSONAL
DATA?
When you sign-up to become a
member of LA18 Fitness 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.
- Contact our Member Services support team
through telephone, email or online chat
- Send an email to an info@la18fit.com
- Complete an Online Membership Agreement
- When you book classes, courses, and
inductions.
- 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 LA18 Fitness /Clubright app
- A question or complaint
- Take part in a competition, prize draw or
survey
- 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.
- When you consent to be contacted
regarding Personal Training
- 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 LA18
Fitness 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:
- Carry out an identity check as part of
your membership application.
- Process your membership application
through Clubright, 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
- 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
LA18 Fitness Ltd. relies on the
following lawful bases for processing, storing and retaining your personal
data:
In relation to your membership
of LA18 Fitness:
1.
your explicit and freely given
consent for the specified purpose of membership and the use of LA18 Fitness
facilities;
2.
the processing is necessary for
the performance of your membership agreement with LA18 Fitness.
3.
the processing is necessary for
a legal obligation that LA18 Fitness is subject to
4.
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
1.
your explicit and freely given
consent for the specified purpose of membership and the use of LA18 Fitness
facilities;
2.
processing is necessary for
reasons of public interest in the area of public health.
3.
processing is necessary to
protect your vital interests
In relation to website visitors
and marketing information
1.
the processing is necessary for
the legitime interest for LA18 Fitness to be able to provide, optimize and
target the website
2.
the processing rely on a
soft-opt in approach for marketing information
3.
your explicit and freely given
consent for new openings
4.
your explicit and freely given
consent for being contacted by a third party, e.g. Personal trainers
5.
the processing is necessary for
the legitimate purposes of LA18 Fitness or by a third party to be able to carry
out direct marketing
6.
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
App
1.
the processing is necessary for
the performance of an agreement, e.g. classbooking etc.
2.
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
3.
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
1.
the processing is necessary for
a legal obligation that LA18 Fitness is subject to
2.
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 LA18 Fitness. 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 LA18 Fitness.
We may contact you about LA18
Fitness 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 LA18 Fitness.
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 LA18 Fitness 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.
LA18 Fitness 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 24 hours by an external CCTV team. Namely Secure24.
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.
LA18 Fitness 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
LA18 Fitness will ensure that the installation complies with this policy and
that the use of any camera is justified, necessary and proportionate. LA18
Fitness 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
LA18 Fitness 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 LA18 Fitness 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 centre.
DO WE USE COOKIES?
LA18 Fitness 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 LA18 Fitness website does
not respond to DNT signals.
COLLECTION OF CHILDREN'S DATA
A LA18 Fitness, 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 info@la18fit.com 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 LA18 Fitness website in the members’ area. Debit, Credit and
Bank account changes can be made in your members’ area on the LA18 Fitness 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 LA18 Fitness 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.