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 legitimate interest. At PureGym we are committed to protecting your privacy.

IDENTITY OF DATA CONTROLLER

PureGym Ltd. is the data controller for the personal data we process about you.

Our contact information is:

PureGym Ltd

First Floor, 10-14 White Lion Street

London, N1 9PD, UK

If you have any queries about this Privacy Notice, please contact us at [email protected]

WHEN DO WE COLLECT PERSONAL DATA?

When you sign-up to become a member of PureGym 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 @puregym.com email account.
• Register your interest for upcoming PureGym opening locations.
• 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.
• When you use the PureGym app.
• Raise a question or complaint to one of our teams.
• 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 involved, were a witness or personally affected. This includes any health and safety, or security incidents.
• When you use equipment in the gym such as Hydro Massage or when you obtain a drink from one of the Yanga Water stations.
• 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 always be asked beforehand).
• We may also collect, match or acquire information about you from other organisations such as Meta, Snapchat, Google, Pinterest and TikTok.

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 PureGym 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.
• Your marketing preferences.

We may process sensitive information, such as your health information, only under very specific circumstances. For example, you have explicitly consented to us collecting this information, or, there has been an incident at one of our gyms.

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 member 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. This is carried out by Bottomline Technologies Ltd and is NOT a credit check
• Process your membership application through Exerp, 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 Meta, Snapchat, Google, Pinterest and TikTok
• 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 or defend ourselves in the event of a civil claim
• Operate our facilities in a safe and secure way

BASIS OF LAWFUL PROCESSING

PureGym Ltd. must have a lawful basis (valid legal reason) to collect and process information about you. We rely on the following lawful bases for processing, storing and retaining your personal data:

In relation to your membership of PureGym:

• Consent: your explicit and freely given consent for the specified purpose of membership and the use of PureGym's facilities;
• Contractual obligations: the processing is necessary for the performance of your membership agreement with PureGym;
• Legal obligations: the processing is necessary for a legal obligation that Puregym is subject to;
• Legitimate interests: the processing is necessary for the legitimate business interests of PureGym to make sure our services are working well, and to improve member experience.

In relation to your health information, or other types of sensitive information:

• Consent: your explicit and freely given consent for the specified purpose of membership and the use of PureGym's facilities;
• Public task: the processing is necessary for reasons of public interest in the area of public health.
• Vital interests: the processing is necessary to protect your life or prevent serious physical harm.

In relation to website visitors and marketing information:

• Consent:
• You have opted-in to receive marketing materials and communications from us.
• You have explicitly and freely given consent for new openings.
• You have explicitly and freely given consent to be contacted by a third party, for example, Personal Trainers.
• Legitimate interests:
• The processing is necessary for the legitimate business interests of PureGym to be able to provide, optimize and target the website.
• The processing is necessary to for the legitimate business interest of PureGym to process a limited amount of data for statistical purposes.
• We may also rely on legitimate interests in order to carry out direct marketing, but only when certain conditions are met, for example, the processing has a minimal impact on your privacy, and you are always offered an opt-out.
• The processing relies on a soft-opt in approach for marketing information.

In relation to users of the PureGym App:

• Contractual obligations: the processing is necessary for the performance of an agreement, e.g. classbooking etc.
• Legitimate interests: the processing is necessary for the legitimate business interest in being able to provide functionality and optimize the App, and services offered through the App, and target ads as well as to communicate with your via the App.

In relation to your retained personal data and debt following termination or cancellation of your membership:

• Legal obligations: the processing is necessary for a legal obligation that PureGym is subject to.
• Legitimate interests: the processing is necessary for the legitimate interest in safeguarding the interest of employees and other members, and commercial interest, in preventing re-membership of a blacklisted individual, and being able to decide when an excluded member can regain membership.

RETENTION

We will store your personal data for as long as it is necessary for the purpose of processing.

This means that we will keep your data for as long as you are a Member of PureGym. Following cancellation or termination of your membership we will keep 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 PureGym. We may contact you about PureGym 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 may retain your personal data for longer if we have a legitimate interest to do so, or to meet legal obligations, including health and safety, financial audit, anti-fraud and money laundering regulations.

CCTV

We process information from CCTV of entrances, reception and fitness areas as well as training halls. No cameras infringe on private areas of the gyms, such as changing rooms.

This section sets out the appropriate actions and procedures which PureGym follows in respect of the use of CCTV (closed circuit television) in our Gyms. Please note that all our gyms are observed by CCTV 24 hours a day.

PureGym 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 observed 24 hours a day by our internal CCTV team.

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.

PureGym’s processing of CCTV is necessary for the legitimate interest in monitoring the gyms as part of the implementation of security measures and to be able to exercise or defence of a civil claim.

Prior to any camera installation PureGym will ensure that the installation complies with this policy and that the use of any camera is justified, necessary and proportionate. PureGym 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, after which they are deleted, 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 to third parties, for example, a police enquiry or request from a lawyer, needs to be supported by a DPA or written authority from the registered person on the images.

OPT OUT

PureGym 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 PureGym 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?

For information on PureGym’s use of Cookies, please refer to our Cookie 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 may use limited personal data, including engagement characteristics and usage data, to help us better understand how you interact with our services. This data may be subject to automated decision-making and profiling, which we use to tailor our offering, marketing communications and improve user experience. Where such processing takes place, we do not make any decisions based on automated decision-making that would produce legal effect or similarly significant impacts on individuals.

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 PureGym website does not respond to DNT signals.

COLLECTION OF CHILDREN'S DATA

At PureGym, 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 Obligations: To provide gym membership services.
• Legal Obligations: To comply with health and safety laws.
• Vital Interests: To keep them safe

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 [email protected] 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 PureGym website in the members’ area. Debit, Credit and Bank account changes can be made in your members’ area on the PureGym 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 PureGym 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 a decision based on solely automatic processing of your personal data, that produces a legal, or similarly significant, effect.

If you wish to make a Data Protection complaint, please reach out the [email protected] mailbox. Alternatively you can contact the Data Protection Commission at Making a complaint with the DPC | Data Protection Commissioner

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.