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Privacy Notice - 10th November 2023

PRIVACY NOTICE

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 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.

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

PureGym Ltd. is registered with the Information Commissioner's Office (the 'ICO') as a data controller under registration reference Z3465837.

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, or contact us with When you use the PureGym 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 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 be asked beforehand)

We may also collect, match or acquire information about you from other organisations such as Google 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 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
  • 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. 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 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 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
  • 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

PureGym Ltd. relies on the following lawful bases for processing, storing and retaining your personal data:

  1. In relation to your membership of PureGym:
    1. your explicit and freely given consent for the specified purpose of membership and the use of PureGym's facilities;
    2. the processing is necessary for the performance of your membership agreement with PureGym
    3. the processing is necessary for a legal obligation that Puregym is subject to
    4. the processing is necessary for the legitimate interest in communicating with members and conducting customer satisfaction.
  2. 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 PureGym's 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
  3. In relation to website visitors and marketing information
    1. the processing is necessary for the legitime interest for PureGym 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 PureGym 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
  4. In relation to users of the PureGym 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
  5. 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 PureGym 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 PureGym. 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 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 will store information until a quarantine period expires for members excluded from training in PureGym.

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 PureGym 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. 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 monitored in unstaffed hours between 8pm and 8am 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.

PureGyms 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 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, 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

PureGym will only send you information relating to your membership and about similar products or services. 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 center.

DO WE USE COOKIES?

PureGym 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 PureGym website does not respond to DNT signals.

COLLECTION OF CHILDREN'S DATA

PureGym does not collect or process the personal data of children under the age of 16.

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 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.