The Conditioning Club Privacy Policy
Introduction
This is our Privacy Policy, which sets out how The Conditioning Club ltd uses and protects any information that you give us when you communicate with us, sign up for any membership or use this Website. By browsing and using our website you are agreeing to comply with and be bound by this Privacy Policy, which together with our Membership Agreement, govern The Conditioning Club Limited’s relationship with you. Please read the following carefully so you can understand how your personal data will be treated.
For the purposes of the UK General Data Protection Regulation (“the Regulation”) and the Data Protection Act 2018, the controller is The Conditioning Club ltd. The term ‘The Conditioning Club’ or ‘us’ or ‘we’ refers to the operator of The Conditioning Club and the owner of the Website whose registered office is Unit 27 Horcott Industrial Estate, Fairford, GL7 4BX. Our company registration number is 073862675 (United Kingdom). The term ‘you’ refers to the user of the gym that we operate or any other visitor to this Website, as the context dictates.
Subject always to your rights under the Regulation, we may update this Privacy Policy from time-to-time. To ensure that you are always aware of our most current Privacy Policy, please take the time to check this page regularly.
The Regulation gives you certain rights which are detailed in the section headed "Your Rights regarding personal information". The contents of this Privacy Notice are subject to these overriding rights and no provision in any other part of this Privacy Notice is to be construed as restricting the scope of those rights.
What information do we collect?
If you are a visitor to our Website, even an anonymous visitor, we may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information internally and externally. This statistical data about browsing actions and patterns does not identify any individual. Nevertheless, to the extent that such information falls to be treated as personal data, and you do not wish us to process it, you should change the settings on your internet browser to prevent collection of this information.
We may collect and process the following data about you:
• Any information that you provide us, including by filling in forms on this Website including but not limited to your name, address, email address and telephone/mobile number, for the purposes of informing you about the services that we offer, of entering into a contract with you and thereafter of delivering the services which we have agreed to provide under that contract.
• Any financial information provided to the Website as may be required for direct debits, and/or credit and debit card payments, or other types of electronic payment. Details of any transactions you carry out through the Website will be recorded.
• Further general information about you, including your personal or professional interests, experiences with our products and services or other products and services and your contact preferences to ensure that you receive services in the manner which is most convenient to you, to deliver a satisfactory service under the terms of our contract with you and to improve the services that we offer for the benefit of you and of other existing and future members.
• Details of your visits to the Website, including, but not limited to, traffic data, location data, weblogs and other communication data. This will assist us in managing the website and generating generalised and anonymised information about usage and about our membership.
We may also retain copies of any correspondence you send to us and details of your membership history, for as long as it is appropriate to do so, and (as with all the personal data we process) subject to appropriate technological and organisational safeguards to protect its integrity.
What do we do with the information we collect?
We use collected information for the purposes of our legitimate interests, including:
• for internal record keeping;
• to manage your membership;
• for product development;
• to provide you with information on our products and services which we feel may interest you;
• to notify you about changes to our products and services;
• to answer your queries;
• to investigate any complaints made, either by you or another person;
• to contact you for market research and analyse the output of such research; and/or
• to make disclosures to law enforcement authorities or other statutory regulators;
• to allow us to establish, exercise or defend our legal rights, and/or
• to allow us to comply (and evidence our compliance) with any legal and regulatory obligations imposed on us.
We may collect and use special category personal data, and in particular, information about your health, with your consent or where you have provided it to us, to allow us to tailor our services to meet your needs and to ensure your health and safety.
We may also process information relating to actual or alleged criminal offences where it is necessary for the safety of staff or members, and only where such use is permitted by the law.
The Conditioning Club does not use your personal information in any automated decision-making process.
Your personal data may be transferred abroad for any of the purposes explained in this policy and such transfer may be to a country outside of the EEA. If we transfer your personal data outside the EEA, it will only be to recipients who offer an adequate level of protection and who have appropriate safeguards in place to protect your personal data. It may also be processed by personnel operating outside the EEA who work for us or for one of our service providers. Again, this will only be where there is an adequate level of protection and who have appropriate safeguards in place to protect your personal data. Countries where personal information relating to you may be stored and/or processed, or where recipients of personal information relating to you may be located, may have data protection laws which differ to the data protection laws in your country of residence. By submitting your personal information, you accept that personal information relating to you may be transferred, stored or processed in this way.
The period of use of the personal data supplied by you will not be longer than we deem necessary to carry out the purpose for which such data was collected, provided that we may store and process your personal data for longer periods solely for archiving or statistical purposes where we have appropriate safeguards in place to protect your rights.
Who do we share this information with?
We do not sell, transfer or disclose personal information we have collected from you in connection with our website activities to third parties outside The Conditioning Club ltd.
How to get copies of or amend the information we have collected
You may request details of personal information which we hold about you under the regulation. If you would like a copy of the information held on you, please contact us by email to info@theconditioningclub.com.
If you think any information we have about you is incorrect or incomplete, please e-mail or write to us and we will correct or update any information as soon as possible.
Security
We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and corporate policies to safeguard and secure the information we collect online. Please be assured that we will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this Privacy Policy. Any transactions will be encrypted. We cannot, however, guarantee the security of your transmitted data and you submit such data at your own risk.
Where we have given you a password to access certain areas of the Website you are responsible for keeping this confidential and we ask that you do not share this password.
CCTV policy
This section sets out the appropriate actions and procedures which The Conditioning Club Ltd follows in respect of the use of CCTV (closed circuit television) surveillance systems (“CCTV Systems”) at Our premises.
Sound recording is disabled on all cameras.
Please note that all our gyms are monitored by CCTV 24 hours a day. The Conditioning Club ltd 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.
In drawing up this policy, due account has been taken of the following:
1. The Regulation and any other relevant Data Protection legislation;
2. The CCTV Code of Practice produced by the Information Commissioner (“Code of Practice”); and
3. The Human Rights Act 1998.
This policy will cover all employees and persons providing a service to The Conditioning Club Ltd, visitors and all other persons whose image(s) may be captured by our CCTV Systems.
We will also ensure that the personal data captured by our CCTV Systems is only processed in accordance with the following requirements:
• It will be processed fairly, lawfully and in a transparent manner;
• It will only be collected for specified, explicit and legitimate purposes and not further processed in any manner incompatible with those purposes;
• It will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• It will be accurate and, where necessary, kept up to date;
• It will not be kept for longer than is necessary for the purposes for which the personal data are processed; and
• It will be processed in a manner that ensures appropriate security of the personal data.
Initial Assessment Procedures
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.
Prior to any camera installation the gym will ensure that the installation complies with this policy and that the use of any camera is justified, necessary and proportionate. The CCTV Officer will regularly assess whether the use of any camera and the CCTV System as a whole continues to be justified, necessary and proportionate.
Siting the Cameras
The location of the equipment is carefully considered because the way in which images are captured needs to comply with the Regulation.
All cameras are located in prominent positions within public view and do not infringe on sensitive areas. All CCTV surveillance is automatically recorded, and any breach of this siting policy will be detected via controlled access to the CCTV System and auditing of the CCTV System.
Quality of the Images
The images produced by the equipment will as far as possible be of a quality that is effective for the purpose(s) for which they are intended. Upon installation, all equipment is tested to ensure that only the designated areas are monitored, and suitable quality pictures are available in live and play back mode.
Processing the images
Images which are not required for the purpose(s) for which the equipment is being used will not be retained for longer than is necessary. While images are retained, it is essential that their integrity be maintained, whether it is to ensure their evidential value or to protect the rights of people whose images may have been recorded. Access to and security of the images is controlled in accordance with the requirements of the Regulation.
All images are digitally recorded and stored securely within the system’s hard drives. Images are stored for a minimum of 14 days and typical for no more than 31 days.
Where the images are required for any other purpose, for example system testing, evidential purposes or disciplinary proceedings, a copy file will be moved to an access controlled confidential location on the network and held until completion of the investigation. Viewing of images within the system is controlled by the gym staff. Only persons trained in the use of the equipment and authorised by the gym owner can access data.
Access to and disclosure of images to third parties
Access to, and disclosure of, the images recorded by our CCTV System and similar surveillance equipment is restricted and carefully controlled. This ensures that the rights of individuals are preserved, and the continuity of evidence remains intact should the images be required for evidential purposes e.g. a police enquiry or an investigation being undertaken as part of an internal procedure.
Access to the medium on which the images are displayed and recorded is restricted to the gym staff authorised and third parties as authorised from time to time for specific purposes. Access to and disclosure of images is permitted only if it supports the purpose for which such images were collected.
Access to images by individuals
The Regulation gives any individual the right to request access to CCTV images which contain their personal data.
CCTV is managed and maintained by a trusted third-party company on behalf of The Conditioning Club Ltd. Individuals who request access to images must submit this formally in writing to us via email. This will provide us with sufficient details to identify the section of footage they are concerned with and to enable The Conditioning Club ltd to satisfy itself that the person making the request is the data subject of that specific recording. Upon receipt of the request, the staff authorised, will determine whether disclosure is appropriate and whether there is a duty of care to protect the images of any third parties. If the duty of care cannot be discharged, then the request can be refused.
A written response will be made to the individual, giving the decision (and if the request has been refused, giving reasons) within 31 days of receipt of the request.
Your rights regarding personal information
The Regulation provides certain overriding rights for data subjects.
You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information (including in relation to direct marketing), to stop unauthorised transfers of your personal information to a third party and, in some circumstances to obtain your personal information in a structured, commonly used and machine-readable format or to have it transferred directly to another organisation. You may also have the right to lodge a complaint in relation to our processing of your personal information with a local supervisory authority.
If you have a concern about the way we are collecting or using personal information relating to you, we request that you raise your concern with us in the first instance: email at info@theconditioningclub.com .
How to contact us
If you have any questions about our Privacy Policy, please contact us via email on info@theconditioningclub.com
Changes to our Privacy, CCTV & Cookie Policy
We may make reasonable changes to this Privacy, CCTV and Cookie Policy at any time. It is your responsibility to check online at regular intervals for changes to this document.
Last updated 28/04/2021