Privacy Policy
EMD Fitness believe in transparency, and are committed to being upfront about privacy practices, including how your personal information is treated. EMD Fitness have undertaken an extensive exercise to ensure ongoing compliance with the European Union General Data Protection Regulation (EU GPDR).
EMD Fitness have ensured all current business processes and procedures are in line with the GDPR rights and principles and any new processes involving personal information that are implemented will be thoroughly reviewed through a Data Protection Impact Assessment (DPIA) prior to proceeding. All company data protection procedures and policies are reviewed on an annual basis to ensure compliance.
This Privacy Policy sets out the data processing practices carried out through the use of the Internet and any other electronic communication networks by EMD Fitness, as well as describing the types of personal information that EMD Fitness may collect about you and the purposes for which this information is used.
1. Accepting the Privacy Policy
2. Information Collected or Received
3. How and why EMD Fitness use your Personal Information
4. Communication from EMD Fitness
5. Sharing your Information
6. Keeping your Information Secure
7. EMD Fitness Retention Policies
8. Staying in Control - Your Rights
9. Privacy Policy Changes
10. Contact
1. ACCEPTING THE PRIVACY POLICY
EMD Fitness need to process your personal information to run their business and provide you with their services. Upon visiting EMD Fitness in the studio, contacting EMD Fitness by telephone, or visiting EMD Fitness website(s), you are accepting and consenting to the practices described in this Privacy Policy.
INFORMATION COLLECTED OR RECEIVED
EMD Fitness collect personal information from studio users, Staff and Suppliers/Sub-contractors to run their business and provide you with their services. This personal information may include the following: name, date of birth, email address, contact number, company name, bank details and credit card details.
EMD Fitness also collect the following information:
Sensitive Information: The term "sensitive information" in this context refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. Whilst EMD Fitness do not generally collect sensitive information unless it is volunteered by you, EMD Fitness do have a legal requirement to collect health data for the purpose of recording your self-assessment declaring readiness for physical exercise.
Photographs and Identification: In the interests of security and the prevention of crime, EMD Fitness may take a digital photograph of each Member or guest. Each Member or guest may also be required to provide a form of identification for verification and security purposes.
Digital: When visiting EMD Fitness website(s), your personal information may be collected, stored and used such as traffic data, location data, web logs, communication data and resources that you access, as well as other personal information detailed above. If you connect to EMD Fitness or register for a tour of EMD Fitness using an external third-party application, such as Facebook, Instagram, or Twitter, these websites will have their own privacy statement which EMD Fitness suggest that you read before giving them your personal information. Connecting to EMD Fitness via a third-party application or service is optional and at your own discretion.
EMD Fitness will only collect the relevant information required for the purposes of processing and will not use this information for any other purpose without obtaining consent.
3. HOW AND WHY EMD Fitness USE YOUR PERSONAL INFORMATION
The information in the above, section 2, may be used for the following purposes:
- To carry out To carry out EMD Fitness’s obligations arising from any contractual agreement;
- To contact you about non-contract aspects of your Membership, such as a change in usage patterns;
- To provide you with the information on products or services you request;
- To process payments and maintain accounts and records;
- To prevent crime, fraud and aid in the prosecution of offenders;
- To maintain Membership records;
- To improve the EMD Fitness platform;
- To prevent or detect abuses of the EMD Fitness website;
- To create business performance statistics and analysis;
- To enable third parties to carry out technical, logistical, research or other functions on behalf of EMD Fitness;
- To send you newsletters and promotions, prize draws, and competitions;
- To conduct surveys and request feedback;
- To notify you about changes to EMD Fitness Services, Terms and Conditions, Privacy Policy and Club rules;
- To process your job application if you apply for employment at EMD Fitness;
- To collect information about your tastes and preferences, both when you tell us and by analysis of customer traffic, including using "cookies";
- To read and respond to comments made regarding EMD Fitness services.
Other than as set out in this Privacy Policy EMD Fitness will not use your personal information for any other purpose without your consent, unless required to do so by law.
4. COMMUNICATION FROM EMD Fitness
On occasion, EMD Fitness may need to contact you. Primarily, these messages are delivered by email, text or phone, and every individual’s record is required to keep a valid email address and contact number on file to receive these messages.
In response to enquiries and when communicating with Members, EMD Fitness believe that the content is relevant, valuable, interesting and beneficial to you. EMD Fitness also believe that you would reasonably expect to receive the type of content that is sent to you as part of your relationship with EMD Fitness.
Therefore, EMD Fitness’s current assessment is that the communication you receive is covered by the lawful basis for processing of ‘Legitimate Interest’ under recital 47 within the GPDR. For all communication sent under the basis of legitimate interest, opt-out options are provided and detailed later within this section.
For all communication where consent is the only legal basis, preferences will be collected in advance.
EMD Fitness recognise that you value having control over your own information, so EMD Fitness gives you the choice of editing your communication preferences if you disagree with the above. For EMD Fitness Members and Ex Members you may update these preferences by logging into the Members area through the login page of the website, (www.showgirlstudios.uk). Alternatively you may email info@showgirlstudios.uk with your request.
Please note the following messages from EMD Fitness fall into the category of compulsory communication and therefore no opt-out options are available:
- Urgent Communication (such as, unplanned closure of all or part of the studio, reduced services, a change of opening times)
- Automatic Class Booking communication (such as, booking confirmation, waiting list movement, cancellations)
- Contract and Subscription related communication (such as, welcome emails, outstanding arrears, upcoming renewals, communication with the EMD Fitness Member Services Support Team).
You may receive communication from EMD Fitness via the following communication systems, all of which offer an opt-out service. Please note you must opt-out of each individual communication system should you wish to exercise that right;
Direct email communication from EMD Fitness staff via Outlook: To opt out you can do either of the following, log into the members area on the website to update your communication preferences within the My Profile section. You can also request this specifically to info@showgirlstudios.uk
5. SHARING YOUR INFORMATION
Information about EMD Fitness Club users is an important part to the business and EMD Fitness do not sell it to others. EMD Fitness shares member information only as described in this Privacy Policy.
Enquiries through EMD Fitness website(s): EMD Fitness capture data through EMD Fitness website(s) hosted by third parties (Simplar Tech). These can be for purchasing a giftcard, booking a tour online, joining online, referring a friend online, PT enquiries online, corporate enquiries online.
Membership System and Bookings App: In order for EMD Fitness to process and manage existing and ex Memberships as well as Prospective Members, they use a third party (Simplar Tech) to provide the membership management system. Class bookings can be processed directly via the website hosted by Simplar Tech.
Payment Collection: EMD Fitness use third parties (Stripe) for payment collection whether that be upfront payment for membership, monthly direct debit payment for membership.
Paperwork Destruction: EMD Fitness schedule regular collections of paperwork from a third party company (The Hill Company) who securely and confidentially shred this paperwork off site, on behalf of EMD Fitness.
EMD Fitness provide anonymous or hashed data to third party advertisers (Facebook), to further understand customer trends and patterns, as well as a way to reach new customers who are likely to be interested in EMD Fitness, due to having similar interests to existing EMD Fitness customers.
Cookies: A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. Find out more about cookies on https://ico.org.uk/for-the-public/online/cookies/
EMD Fitness use cookies to identify you when you visit this website and to keep track of your browsing patterns, to build up a demographic profile and to use for advertising purposes. EMD Fitness use cookies to allow registered users to be presented with a personalised version of the site, carry out transactions and have access to information about their account. Most browsers will allow you to turn off cookies. If you want to know how to do this please look at the menu on your browser, or look at the instruction on https://ico.org.uk/for-the-public/online/cookies/. Please note however that turning off cookies may restrict your use of our website. By continuing to use this site you are agreeing to the use of cookies as detailed within this section.
6. KEEPING YOUR INFORMATION SECURE
In regards to environmental and physical security, all EMD Fitness employees receive full training upon commencement on employment and subsequently on an annual basis thereafter. This is completed via an e-learning platform and group training sessions. Further to this, daily, weekly and monthly audits are completed.
7. EMD Fitness RETENTION POLICIES
EMD Fitness have set company retention policies in place and these timescales are set in accordance with any applicable legislation and/or for any agreed legitimate reasons. Where none exists, then EMD Fitness will keep your information for the duration of any Contract that you have entered into with EMD Fitness, and then for a period of 7 years after, at which time all the personal information will be pseudonymised.
After that 7 year duration, EMD Fitness will retain and use your pseudonymised information for the purpose of business statistics and analysis. EMD Fitness can retract this pseudonymisation to the extent necessary to comply with any legal obligations or to resolve disputes
8. STAYING IN CONTROL - YOUR RIGHTS
EMD Fitness understand the importance of data subjects remaining in control of their personal data. EMD Fitness acknowledge the following rights you have under the GDPR, what they mean and how you can exercise them.
The Right to be Informed
This privacy policy states all uses of your personal information and the purposes for processing this information. Should you have any concerns or questions about our privacy policy and practices, or would like a full list of our third party processors, then please email info@showgirlstudios.uk
The Right of Access
You have the right to access information that EMD Fitness hold about you. If you wish to receive a copy of the information that EMD Fitness hold, please submit a Subject Access Request form (SAR) which you can request from info@showgirlstudios.uk. Once EMD Fitness have received your form, they will provide a response within one month. If your request is unusually complex and likely to take longer than a month, you will be informed as soon as possible to tell you how long it’s likely to take.
Please note that whilst in most cases EMD Fitness will be happy to provide you with copies of the information you request, EMD Fitness nevertheless reserve the right, in accordance with section 8(2) of the DPA, not to provide you with copies of information requested if to do so would take “disproportionate effort”, or in accordance with Article 12 of the GDPR to charge a fee or refuse the request if it is considered to be “manifestly unfounded or excessive”.
The Right to Rectification, Restrict Processing, Erasure, and to Object
You can ask EMD Fitness at any time to change, amend or pseudonymise the information that EMD Fitness hold about you or restrict ways in which your data may be processed. You can update EMD Fitness with amendments of personal information by submitting a request through the member services area of our website using the following link, https:www.showgirlstudios.uk/login
To pseudonymise the information, or object/request restriction of processing then please email info@showgirlstudios.uk
EMD Fitness will aim to respond to any request as soon as possible, but no later than within 1 month since receipt of request. Please note that the right to erasure is not absolute and only applies in certain circumstances. For further information on this please visit the following link to the ICO’s website, https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Right to Data Portability
You have the right to request that your personal data is transferred by EMD Fitness to another organisation (this is called “data portability”). Please contact us at info@showgirlstudios.uk with the details of what you would like for EMD Fitness to do and EMD Fitness will endeavour to comply with your request. It may not be technically feasible, but EMD Fitness will work with you to try and find a possible solution.
Right to Prevent Automated Decision Making
You have a right to ask EMD Fitness to stop any automated decision making. EMD Fitness do not intentionally carry out such activities, but if you do have any questions or concerns EMD Fitness would be happy to discuss them with you so please email any concerns or queries to info@showgirlstudios.uk
9. PRIVACY POLICY CHANGES
EMD Fitness may make slight changes to the Privacy Policy, Terms and Conditions and studio Rules, however, will never materially change policies and practices to make them less protective of member information collected in the past without the consent of affected members. EMD Fitness will display signage with details of any changes to these notices and conditions, but an up to date version will always be available on the website (www.showgirlstudios.uk).
10. CONTACT
If you have any questions, comments or concerns about data privacy at EMD Fitness, please e-mail thorough a description toinfo@showgirlstudios.uk and EMD Fitness will endeavour to resolve the issue for you. Alternatively should you wish to escalate any concerns or questions, rather than contact EMD Fitness directly, please contact the supervisory authority The Information Commissioner’s Office (ICO). For more information please visit the ICO’s website https://ico.org.uk/.
