WHEN DO WE COLLECT PERSONAL DATA?
When you sign-up to become a member of Emsworth Gym 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:
- Contact our Member Services support team through email
- Send an email to admin@emsworthgym.co.uk email account
- 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 clubright app
- A question or complain
- Enter your PIN number or QR code 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 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 Emsworth Gym 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:
- Process your membership application through Club right, 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
Emsworth Gym Ltd. relies on the following lawful bases for processing, storing and retaining your personal data:
In relation to your membership of Emsworth Gym:
your explicit and freely given consent for the specified purpose of membership and the use of Emsworth Gym facilities;
the processing is necessary for the performance of your membership agreement with Emsworth Gym
the processing is necessary for a legal obligation that Emsworth Gym is subject to
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
your explicit and freely given consent for the specified purpose of membership and the use of Emsworth Gym's facilities;
processing is necessary for reasons of public interest in the area of public health.
processing is necessary to protect your vital interests
In relation to website visitors and marketing information
the processing is necessary for the legitime interest for Emsworth Gym to be able to provide, optimize and target the website
the processing rely on a soft-opt in approach for marketing information
your explicit and freely given consent for new openings
your explicit and freely given consent for being contacted by a third party, e.g. Personal trainers
the processing is necessary for the legitimate purposes of Emsworth Gym or by a third party to be able to carry out direct marketing
the processing is necessary for the legitimate interest to process a limited amount of data for statistical purposes
In relation to users of the Club right App
the processing is necessary for the performance of an agreement, e.g. classbooking etc.
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
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
the processing is necessary for a legal obligation that Emsworth Gym is subject to
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 Emsworth Gym. 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 Emsworth Gym.
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 Emsworth Gym 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.
Emsworth Gym 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.
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.
Emsworth Gym 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.
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
If you cancel your membership with Emsworth Gym 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?
Emsworth Gym 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.
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
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.